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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

Venugopal Ravichandran, Chennai vs. ITO, Non Corp Ward 19(6)M Chennai, Chennai

In the result, the appeal of the assessee is allowed

ITA 2121/CHNY/2025[2016-17]Status: DisposedITAT Chennai25 Sept 2025AY 2016-17

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.2121/Chny/2025 Assessment Years: 2016-17 Venugopal Ravichandran Income Tax Officer, Old No.5, New No.7, Bhavani Street, Non Corp Ward-19(6), Bharathi Nagar, Tharamani, Ttti, Chennai. Taramani S.O, Taramani, Chennai-600 113. [Pan: Adypr7701G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr.T.S.Lakshmi Venkataraman,Fca प्रत्यर्थी की ओर से /Revenue By : Mr.Saujanya Ranjan, Irs सुनवाई की तारीख/Date Of Hearing : 24.09.2025 घोषणा की तारीख /Date Of Pronouncement : 25.09.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Mr.T.S.Lakshmi Venkataraman,FCAFor Respondent: Mr.Saujanya Ranjan, IRS
Section 147Section 148Section 151ASection 37

151A of the Act r.w. notification dated 29.03.2022 of Central Board of Direct Taxes, reassessment notice u/s 148 was to be issued by the faceless assessing officer and that issuance of the same by the jurisdictional assessing officer u/s 148 dated 30.03.2023 was unwarranted and not in conformity with statutory ... that consequent to notification dated 29th March 2022 issued by the Central Board of Direct Taxes, reassessment u/s 148 can be issued by a faceless assessing officer only. It was urged that in the present case as the notice u/s 148 dated 30.03.2023 was issued by the jurisdictional assessing officer

Oruvandur Pacb Ltd, Namakkal vs. ITO, Ward 2, Namakkal

In the result, the appeal of the assessee is allowed

ITA 2117/CHNY/2025[2019-20]Status: DisposedITAT Chennai25 Sept 2025AY 2019-20

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.2117/Chny/2025 Assessment Years: 2019-20 Oruvandur Pacb Ltd, Income Tax Officer, Orunvandur Po, Ward-2, Namakkal, Namakkal Tamil Nadu-637015, [Pan: Aaaao0407C] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr.T.S.Lakshmi Venkataraman, C.A प्रत्यर्थी की ओर से /Revenue By : Mr.Saujanya Ranjan, Irs सुनवाई की तारीख/Date Of Hearing : 24.09.2025 घोषणा की तारीख /Date Of Pronouncement : 25.09.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Mr.T.S.Lakshmi Venkataraman, C.AFor Respondent: Mr.Saujanya Ranjan, IRS
Section 147Section 148Section 148ASection 151Section 151ASection 80P

151A of the Act r.w. notification dated 29.03.2022 of Central Board of Direct Taxes, reassessment notice u/s 148 was to be issued by the faceless assessing officer and that issuance of the same by the jurisdictional assessing officer u/s 148 dated 30.03.2023 was unwarranted and not in conformity with statutory ... that consequent to notification dated 29th March 2022 issued by the Central Board of Direct Taxes, reassessment u/s 148 can be issued by a faceless assessing officer only. It was urged that in the present case as Page - 2 - of 9 the notice u/s 148 dated 30.03.2023 was issued

Manimala, Puducherry vs. ITO, Ward-3, Puducherry

In the result, the appeal of the assessee is allowed

ITA 2102/CHNY/2025[2019-20]Status: DisposedITAT Chennai25 Sept 2025AY 2019-20

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.2102/Chny/2025 Assessment Years: 2019-20 Manimala Income Tax Officer, 50A Saint Simone Pet, Ward-3, Muthialpet, Pondicherry Pondicherry-605 003. [Pan: Baspm8411L] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr.Suraj Nahar, C.A प्रत्यर्थी की ओर से /Revenue By : Mr.Saujanya Ranjan, Irs सुनवाई की तारीख/Date Of Hearing : 23.09.2025 घोषणा की तारीख /Date Of Pronouncement : 25.09.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Mr.Suraj Nahar, C.AFor Respondent: Mr.Saujanya Ranjan, IRS
Section 147Section 148Section 148ASection 151Section 151ASection 45

151A of the Act r.w. notification dated 29.03.2022 of Central Board of Direct Taxes, reassessment notice u/s 148 was to be issued by the faceless assessing officer and that issuance of the same by the jurisdictional assessing officer u/s 148 dated 29.03.2023 was unwarranted and not in conformity with statutory ... dated 29th March 2022 issued by the Page - 2 - of 9 Central Board of Direct Taxes, reassessment u/s 148 can be issued by a faceless assessing officer only. It was urged that in the present case as the notice u/s 148 dated 29.03.2023 was issued by the jurisdictional assessing officer

Innovative Textiles Limited, Delhi vs. DCIT, Circle-10(1), New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 1160/DEL/2022[2017-18]Status: DisposedITAT Delhi24 Sept 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Innovative Textiles Limited, Vs. Dcit, Circle 10(1), 81, Vighyan Vihar, New Delhi. Delhi – 110 092. (Pan : Aaaci0473J) (Appellant) (Respondent) Assessee By : Shri Gautam Jain, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 05.08.2025 Date Of Order : 24.09.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against Assessment Order Dated 26.03.2022 Passed By The Income Tax Department/National Faceless Assessment Centre, Delhi U/S 143(3) Read With Section 144C(13)/144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2017-18 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :- “1. That The Orders Of The Learned Lower Tax Authorities Is/Are Contrary To The Law & Facts Of The Case.

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR
Section 115JSection 143(3)Section 144BSection 144C(13)Section 144C(5)Section 234ASection 270A

S.RIFAUR RAHMAN, ACCOUNTANT MEMBER : 1. This appeal is filed by the assessee against assessment order dated 26.03.2022 passed by the Income Tax Department/National Faceless assessment Centre, Delhi u/s 143(3) read with section 144C(13)/144B of the Income-tax Act, 1961 (for short ‘the Act”) for Assessment Year

Nand Kumar Choudhary, Bargarh vs. Income Tax Officer, Ward Bargarh, Bandu Vikira Chowk

In the result, appeal of the assessee is allowed

ITA 420/CTK/2025[2016-17]Status: DisposedITAT Cuttack22 Sept 2025AY 2016-17

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.420/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2016-2017) Nand Kumar Choudhury Vs Ito, Ward- Bargarh, Bargarh Rengalapali Camp, Attabira, Baragarh, 768027 Pan No. : Aaqpc 1181 Q (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Shri Sunil Surana, Advocate राजस्व की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 22/09/2025 घोषणा की तारीख/Date Of Pronouncement : 22/09/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Ld.Cit(A), National Faceless Appeal Centre(Nfac), Delhi Order Dated 06/05/2025 Passed In Appeal No. Nfac/2015-16/10166862 For The Assessment Year 2016-2017. 2. It Was Submitted By The Ld. Ar That The Assessment Order In The Case Of Assessee Has Been Passed By The Nfac On 28.03.2022. It Was The Submission That The Notification By Which The National Faceless Assessment Centre Was Made Effective Is Dated 29.03.2022. It Was The Submission That Consequently The Assessment Order Passed On 28.03.2022 Is Liable To Be Quashed. Ld. Ar Placed Reliance On The Decision Of The Coordinate Bench Of The Tribunal In The Case Of Md. Mahimud Sk In Ita Nos.2230&2229/Kol/2024 Pronounced On 04.03.2025, Wherein In Para 10 To 12, The Coordinate Bench Of The Tribunal Has Held As Under :-

For Appellant: Shri Sunil Surana, AdvocateFor Respondent: Shri Vijay Singh, Sr. DR
Section 142(1)Section 143(2)Section 144BSection 147Section 148Section 151A

case of assessee has been passed by the NFAC on 28.03.2022. It was the submission that the Notification by which the National Faceless Assessment Centre was made effective is dated 29.03.2022. It was the submission that consequently the assessment order passed on 28.03.2022 is liable to be quashed ... 144B of the Act vide order dated 23.03.2022. 011. We have perused the section of Section 151A of the Act, which deals with the faceless assessment of income escaping assessment and was brought on the statute book by taxation and other law (realization and amendment of certain provisions