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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

Diosma Lifesciences Private Limited, Mumbai vs. Income Tax Officer Ward 4(1) Thane, Thane

In the result, the appeal of the assessee is dismissed

ITA 4271/MUM/2025[2018-19]Status: DisposedITAT Mumbai16 Sept 2025AY 2018-19

Bench: Ms. Kavitha Rajagopal & Shri Prabhash Shankardiosma Lifesciences Private V/S. Income Tax Officer, Ward – Limited बनाम 4(1), Qureshi Mansion, Shop No. 77, C-Wing, Gokhale Road, Naupada, Harmony Mall Commercial Thane West, Thane - 400 Premises, Bhagat Singh Nagar 602, Maharashtra No.1, Link Road, Goregaon(West), Mumbai - 400 104, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aafcd0525R Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Vipul Shah, ARFor Respondent: Shri Aadesh Rai, Addl. CIT, (Virtually appeared)
Section 133(6)Section 143(2)Section 143(3)Section 37(1)

Appellant without appreciating the fact that the assessment was completed during the peak of the COVID-19 pandemic under the newly introduced faceless assessment scheme, and the alleged non- compliance stemmed from a lack of proper communication due to non- receipt of notices. 3. On the facts and circumstances ... assessee without appreciating the fact that the assessment was completed during the peak of the COVID-19 pandemic under the newly introduced Faceless assessment scheme and the alleged non-compliance stemmed from a lack of proper communication due to non-receipt of notices. 3.1 We have gone through the records

Bmw India Pvt Ltd, Haryana vs. ACIT Circle1(1), Gurgaon

In the result, Appeal of the Assessee is allowed

ITA 2024/DEL/2022[2011-12]Status: DisposedITAT Delhi12 Sept 2025AY 2011-12

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.Bmw India Pvt. Ltd. Vs Assistant Commissioner 2Nd Floor, Oberoi Centre Of Income Tax, Circle (1), Building No. 11, Dlf Cyber Hsiidc Building, Vanijya City Dlf Phase, Gurgaon, Nikunj Udhyog Vihar, Haryuana, 122001 Phase-5, Gurgaon, Pan: Aabcb7140C Haryana Appellant Respondent Assessee By Sh. Himanshu S. Sinha-Adv, Ms. Kanika Jain, Adv& Sh. Prashant Meharchandani, Adv Revenue By Sh. S. K. Jadhav, Cit- Dr Date Of Hearing 06/08/2025 Date Of Pronouncement 12/09/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Challenging The Final Assessment Order Passed By Assistant Commissioner Of Income Tax, Circle -1(1)-Gurgaon, Dated 28/06/2022 U/S254R.W. Section 143(3)/144C Of The Income Tax Act, 1961 ('Act' For Short).

Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153Section 254Section 254rSection 92C

India) (P.) Ltd, Gurgaon Vs. ACIT, Circle-10(1), New Delhi (ITA No. 1733/Del/2022) held as under:- “17. In the context of faceless assessment process time and place of dispatch and receipt of electronic document (in this case DRP order) is required to be ascertained by reference to section ... orders, notices and decisions have to be necessarily uploaded on the ITBA portal and as part of the larger faceless assessment regime which now holds the field. The uploading of the directive of the DRP on the ITBA portal would thus constitute valid and sufficient service and 7 BMW India