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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

Kesar Buildcon Private Limited, Banaskantha vs. The PCIT, Ahmedabad-3, Ahmedabad

Accordingly, we set aside the order passed by the PCIT and restore the assessment order passed by the Assessing Officer. The appeal of the assessee is thus allowed

ITA 790/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad08 Sept 2025AY 2021-22

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2021-2028 Kesar Buildcon Pvt. Ltd. The Ld.Pr.Cit 1St Floor Shri Kesar Cold Vs. Ahmedabad-3 Storage Plot No.B-2 To 9, Rev Survey No.85/2 Paiki Near Hotel Jyoti Vil Banaskantha. Pan : Aabck 4923 E (Applicant) (Responent) : Shri Hem Chhajed, Ar Assessee By : Shri Rignesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 03/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 08/09/2025

For Appellant: Shri Rignesh Das, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 2(22)(e)Section 263Section 269S

dated 17.05.2021 and copy of Instruction No. 1 dated 13.10.2021 issued by the CBDT, which lays down the modalities for conducting assessments under the Faceless Assessment Scheme and delineates the scope of limited scrutiny, complete scrutiny and compulsory scrutiny cases. Point No. 10, as reproduced from the Instruction, reads ... there was no conversion of the case into complete scrutiny with approval of the PCIT. This is also in conformity with the scheme of faceless assessment. 5.5 We have referred to Notification No. S.O. 2745(E) dated 13.08.2020, wherein paragraph 5(i) specifically provides that the National e-Assessment Centre

Mrs. Roopa Rathi, Chennai vs. ITO, Ncw-10(3), Chennai

In the result, the appeal of the assessee is allowed

ITA 1707/CHNY/2025[2018-19]Status: DisposedITAT Chennai04 Sept 2025AY 2018-19

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1707/Chny/2025 Assessment Years: 2018-19 Mrs.Roopa Rathi, Income Tax Officer, Door No.1, Damodar Murthy Street, Non-Corporate Ward-10(3), Kilpauk, Chennai. Chennai-600 010. [Pan: Ajapr6077R] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr.Hitesh, Advocate For Mr.D.Anand, Advocate. प्रत्यर्थी की ओर से /Revenue By : Ms.Gouthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 25.08.2025 घोषणा की तारीख /Date Of Pronouncement : 04.09.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Mr.Hitesh, Advocate for Mr.D.AnandFor Respondent: Ms.Gouthami Manivasagam, JCIT
Section 147Section 148Section 148ASection 151Section 151ASection 68

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 30.03.2022 was unwarranted and not in conformity with statutory ... dated 29th March 2022 issued by the Central Board of Direct Taxes, reassessment u/s 148 can be issued by a Page - 2 - of 9 faceless assessing officer only. It was urged that in the present case as the notice u/s 148 dated 30.03.2022 was issued by the jurisdictional assessing officer

Microsoft Corporation (India) Pvt Ltd, Delhi vs. DCIT (16) (1) Delhi, Delhi

Appeal of the assessee is allowed

ITA 1862/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Sept 2025AY 2017-18

Bench: Shri Mahavir Singh, Vice Presdient (), Shri Vikas Awasthy & Shri Brajesh Kumar Singhआअसं.1862/िद"ी/2022 (िन.व. 2017-18) Microsoft Corporation (India) P. Ltd., 807, New Delhi House, Barakhamba Road, New Delhi 110001 ...... अपीलाथ"/Appellant Pan: Aaacm-5586-C बनाम Vs. Deputy Commissioner Of Income-Tax, Circle 16(1), Central Revenue Building, ..... "ितवादी/Respondent Ip Estate, Delhi अपीलाथ" "ारा/ Appellant By : S/Shri Nageswar Rao, (Through Vc) & Parth, Advocates "ितवादी"ारा/Respondent By : Shri Rajesh Kumar, Cit- Dr सुनवाई क" ितिथ/ Date Of Hearing : 04/09/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 04/09/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 30.06.2022, Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961, (Hereinafter Referred To As ‘The Act’) For Assessment Year 2017-18. 2. Shri Nageswar Rao, Appearing On Behalf Of The Assessee Submitted At The Outset That, At This Stage He Is Confining His Submissions To Ground No. 1 Of Appeal

For Appellant: S/Shri Nageswar Rao, (Through VC) &For Respondent: Shri Rajesh Kumar, CIT- DR
Section 143(3)Section 144C(13)Section 144C(5)

Referring to the directions of DRP, he pointed that in the instant case a copy of directions were endorsed to Principal CIT, National Faceless Assessment Centre Delhi, the Commissioner of Income Tax, TP-2, Delhi, the Additional/Joint/Deputy/ Assistant CIT, National Faceless Assessment Centre, Delhi and the TPO but the directions ... benefit of same at the cost of Revenue. Referring to the decision of Hon’ble Supreme Court of India in the case of National Faceless Assessment Centre & Others vs. Automotive Manufacturers Pvt. Ltd. in Civil Appeal No. 1829/2023 decided on 21.03.2023, he prayed for restoring the matter back

DCIT, CC-3, Ludhiana, Kitchlu Nagar vs. Mani Ram Balwant Rai HUF, Civil Lines

In the result, Cross Objection filed by the assessee is allowed and appeal of the Revenue is dismissed

ITA 1042/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh01 Sept 2025AY 2019-20

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 1042/Chd/2024 "नधा"रण वष" / Assessment Year: 2019-20 The Dcit, Mani Ram Balwant Rai, Huf, Central Circle-3, Vs Civil Lines, Opposite Session Court(Old) Kitchlu Nagar, Ludhiana. Ludhiana. "थायी लेखा सं./Pan No: Aaghm1535C अपीलाथ"/Appellant ""यथ"/Respondent & C.O. 43/Chd/2024 In आयकर अपील सं./ Ita No. 1042/Chd/2024 "नधा"रण वष" / Assessment Year: 2019-20 Mani Ram Balwant Rai, Huf, The Dcit, Civil Lines, Opposite Session Court(Old) V Central Circle-3, Ludhiana. S Kitchlu Nagar, Ludhiana. "थायी लेखा सं./Pan No: Aaghm1535C अपीलाथ"/Appellant ""यथ"/Respondent Revenue By : Smt. Kusum Bansal, Cit Dr Assessee By : Shri Pankaj Bhalla, Ca & Shri Hunny Bajaj, Advocate Date Of Hearing : 17.07.2025 Date Of Pronouncement : 01.09.2025 Hybrid Hearing O R D E R Per Rajpal Yadav, Vp

For Appellant: Shri Pankaj Bhalla, CA and Shri Hunny Bajaj, AdvocateFor Respondent: Smt. Kusum Bansal, CIT DR
Section 132(1)Section 147Section 148Section 148ASection 151Section 151A

being reproduced herein below for ready reference of this Hon'ble Court: Section 151 A. Section - 151A, Income-tax Act, 1961 – FA 2023 [Faceless assessment of income escaping assessment.] 151 A. (1) The Central Government may make a scheme, by notification in the Official Gazette, for the purposes of assessment ... Officer is not at all legally competent to issue 148 Notice itself and the 148 Notice was required to be issued by the National Faceless Assessment Centre. D.8 Heavy Reliance is being placed on the Judgment of Jurisdictional Hon'ble Court of Punjab and Haryana in the case of 'Jasjit