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“faceless assessment”

Assessment ProceduresSection 144BSection 144B2,420 judgments

The decision most relied on for faceless assessment is Kankanala Ravindra Reddy v. ITO (156 Taxmann.com 178), cited in 213 judgments on BharatTax.

Leading authorities on faceless assessment

Kankanala Ravindra Reddy v. ITO
156 Taxmann.com 178 · 2023 · High Court
213
citing judgments

A notice issued under section 148 of the Income Tax Act is invalid if the Income Tax Department fails to follow the prescribed procedures, including obtaining the necessary approvals under section 151 or adhering to the faceless assessment scheme mandates under section 151A.

Jatinder Singh Bhangu v. Union of India
165 Taxmann.com 115 · 2024 · High Court
106
citing judgments

The faceless assessment scheme under Section 151A applies from the stage of issuing show cause notices under Sections 148 and 148A, and non-compliance with the scheme or related notifications vitiates the subsequent assessment proceedings. Assessment proceedings are considered to commence upon the issuance of such a show cause notice.

Ram Narayan Sah v. Union of India
163 Taxmann.com 478 · 2024 · High Court
97
citing judgments

A notice under section 148 of the Income-tax Act, 1961, cannot be issued by the Jurisdictional Assessing Officer after the introduction of faceless assessment under Section 151A read with Section 144B. Such a notice is invalid as it defeats the object of faceless assessment and is not in consonance with CBDT notifications.

T.K.S. Builders (P) Ltd. v. ITO
469 ITR 657 · 2024 · High Court
88
citing judgments

Section 144B of the Income Tax Act does not completely divest the Jurisdictional Assessing Officer (JAO) of their power to assess or reassess, even with the introduction of the Faceless Reassessment Scheme.

Triton Overseas (P) Ltd. v. Union of India
156 Taxmann.com 318 · 2023 · High Court
55
citing judgments

A notice under Section 148 for income escaping assessment issued by the Jurisdictional Assessing Officer is invalid if it does not comply with Section 151A and relevant CBDT notifications concerning faceless assessment.

Pvt. Ltd. v. DCIT
466 ITR 474 · 2024 · High Court
53
citing judgments

Reassessment notices under Section 148A, issued in the context of faceless assessment proceedings, must be issued by the designated Faceless Assessing Officer and not by a Jurisdictional Assessing Officer.

Mark Studio India (P.) Ltd. v. Income-tax Officer, High Court of Madras
169 Taxmann.com 542 · 2024 · High Court
50
citing judgments

The National Faceless Assessment Centre (NaFAC) does not have the power to issue notices under Section 148 or 148A of the Income Tax Act. Its jurisdiction for assessment or reassessment begins only from the stage of issuing notices under Section 142(1) or 143(2).

Samp Furniture (P) Ltd. v. ITO
165 Taxmann.com 581 · 2024 · High Court
50
citing judgments

The issuance of a notice under section 148A, including the order under section 148A(d), is a mandatory procedural step before reassessment proceedings can be initiated under section 147/148. Failure to comply with this requirement renders the subsequent reassessment proceedings invalid.

Judgments citing faceless assessment

Viswanathan Pappathi, Vellore vs. ITO, Ward-2, Vellore

In the result, appeal filed by the assessee is allowed

ITA 1620/CHNY/2025[2016-17]Status: DisposedITAT Chennai08 Oct 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S.R.Raghunathaआयकर अपील सं./Ita No.: 1620/Chny/2025 िनधा#रण वष# / Assessment Year: 2016-17 Viswanathan Pappathi Income Tax Officer No. 24C, Pudupet Road, Vs. Ward – 2, 4Th Street, Tirupattur, Vellore. Vellore – 635 601. Tamil Nadu. [Pan: Ceqpp-4595-H] (अपीलाथ%/Appellant) (&'थ%/Respondent) अपीलाथ% की ओर से/Appellant By : Ms. T. V. Muthu Abirami, Advocate &'थ% की ओर से/Respondent By : Shri. N. Rajakumar, Addl. C.I.T.

For Appellant: Ms. T. V. Muthu Abirami, AdvocateFor Respondent: Shri. N. Rajakumar, Addl. C.I.T
Section 144BSection 147Section 148Section 148ASection 151ASection 69A

issued by the jurisdictional Assessing Officer, Income Tax :-3-: ITA. No:1620/Chny/2025 Officer, Ward 2, Vellore. Thereafter, the assessment is completed by the National Faceless Assessment Centre, by making an addition of Rs.76,40,000/- u/s.69A as unexplained money u/.69A and a demand of Rs.65,02,900/- was raised. Aggrieved ... erroneous, since it makes no difference to the validity of the reopening notice, whether it is the jurisdictional Assessing Officer or the National Faceless Assessment Centre and prayed that the appeal be dismissed. She :-4-: ITA. No:1620/Chny/2025 further relied upon para 8 of the order the Hon’ble jurisdictional

Baljit Singh Gambhir, Mumbai vs. Income Tax Officer, International Taxation, Ward-2(3)(1), Mumbai

In the result, assessee’s appeal is allowed for statistical purposes

ITA 912/MUM/2025[2019-20 ]Status: DisposedITAT Mumbai30 Sept 2025

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No.912/Mum/2025 (निर्धारण वर्ा/Assessment Year: 2019-20) Baljit Singh Gambhir V/S. Income Tax Officer, C/O Tejmohan Singh, बिधम International Taxation, Advocate 527, Sector Ward 2(3)(1), Mumbai 10-D, Chandigarh Income Tax Officer, 160011 International Taxation, Ward 2(3)(1), Mumbai 400076 स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No: Amgpg9637H Appellant/अपीलधथी .. Respondent/प्रनिवधदी निर्धाररिी की ओर से /Assessee By: Shri. Tejomohan Singh, Adv. रधजस्व की ओर से /Revenue By: Shri. Krishna Kumar (Sr Dr) सुिवधई की िधरीख / Date Of Hearing 29.07.2025 घोर्णध की िधरीख/Date Of Pronouncement 30.09.2025

For Appellant: Shri. Tejomohan Singh, AdvFor Respondent: Shri. Krishna Kumar (SR DR)
Section 144C(5)Section 148Section 148A

Officer is not legally competent to issue notice under section 148 of the Act as the same was required to be issued by National Faceless Assessment Centre and as such the proceedings initiated are illegal, arbitrary and unjustified. P a g e | 2 ITA No. 912/Mum/2025 AY 2019-20 Baljit