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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

Ayodhya Singh, Jamshedpur vs. Assessment Unit, National Faceless Assessment Unit, Income Tax Department, Ranchi

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 366/RAN/2024[2018-19]Status: DisposedITAT Ranchi22 Aug 2025AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Ratnesh Nandan Sahayi.T.A. No. 366/Ran/2024 Assessment Year: 2018-2019 Ayodhya Singh,……..……………………………..Appellant G-1 & 2, Gangotri House, 1 Number Sura Bhawan Area, South Park, Bistupur-831001, Jharkhand [Pan:Fdjps1783K] -Vs.- Assessment Unit,……………………………..…...Respondent National Faceless Assessment Unit, Income Tax Department, Aayakar Bhawan, 5A, Main Road, Besides Ranchi Club Ltd., Ranchi, Jharkhand Appearances By: Shri P.S. Paul, A.R., Appeared On Behalf Of The Assessee Shri Khubchand T. Pandya, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: July 21, 2025 Date Of Pronouncing The Order: August 25, 2025 O R D E R

Section 10Section 115BSection 142Section 142(1)Section 148Section 148ASection 69A

Singh,……..……………………………..Appellant G-1 & 2, Gangotri House, 1 Number Sura Bhawan Area, South Park, Bistupur-831001, Jharkhand [PAN:FDJPS1783K] -Vs.- Assessment Unit,……………………………..…...Respondent National Faceless Assessment Unit, Income Tax Department, Aayakar Bhawan, 5A, Main Road, Besides Ranchi Club Ltd., Ranchi, Jharkhand Appearances by: Shri P.S. Paul, A.R., appeared on behalf ... Copies to :(1) Ayodhya Singh, G-1 & 2, Gangotri House, 1 Number Sura Bhawan Area, South Park, Bistupur-831001, Jharkhand (2) Assessment Unit, National Faceless Assessment Unit, Income Tax Department, Aayakar Bhawan, 5A, Main Road, Besides Ranchi Club Ltd., Ranchi, Jharkhand (3) CIT(Appeals), NFAC, Delhi

Aamya Resources LLP, Andheri East vs. ITO, Ward 24(1)(1) Mumbai, Mumbai

In the result, the appeal filed by the assessee stands allowed

ITA 4423/MUM/2025[2016-17]Status: DisposedITAT Mumbai21 Aug 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain & Shri Om Prakash Kantvs. Ito, Ward 24(1)(1) Aamya Resources Llp Piramal Chamber, 1, Wilson House, Old Mumbai – 400012. Nagardas Road, Andheri (E), Mumbai – 400069. Pan/Gir No. Abcfa4651A (Applicant) (Respondent) Assessee By Shri Satish Aggarwal (Virtually Appear) Revenue By Shri Surendra Mohan, Sr. Dr Date Of Hearing 21.08.2025 Date Of Pronouncement 24.09.2025 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 11.10.2019 Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The National Faceless Appeal Centre / Cit(A), Mumbai For The Assessment Year 2015- 16. 2. Although, Assessee Had Raised Number Of Grounds In The Present Appeal But At The Outset Ld. Ar Pressed Ground No.4 Which Is Legal In Question & It Goes To The Roots Of The Case. Therefore, We Have Decided To Adjudicate This Ground Firstly, Ground No. 4, Which Is Reproduced Herein Below:

Section 148Section 149Section 151Section 250Section 3(1)

taken; approval granted by Principal Commissioner could not be termed as valid/legal approval. 7 Aamya Resources LLP, Mumbai (iii) Aakruti Ketan Mehta Vs. National Faceless Assessment Centre, [[2025] 173 taxmann.com 265 (Mumbai - Trib.) (Copy of Judgement enclosed in paper Book at page no. 54-59) Where notice under section ... ACIT [2025] 173 taxmann.com 182 (Mumbai - Trib.) 4. DCIT Vs. SS Jewellery [2025] 173 taxmann.com 189 (Mumbai - Trib.) 5. Aakruti Ketan Mehta Vs. National Faceless Assessment Centre, [[2025] 173 taxmann.com 265 (Mumbai - Trib.) 9 Aamya Resources LLP, Mumbai 6. Cipla Pharma and Life Sciences Ltd. vs DCIT [2024] 164 taxmann.com

Tyspl 100 Andimadam Paccs Limited, Andimadam vs. Commissioner of Income Tax Appeal, Chennai

In the result, the appeal of the assessee is allowed

ITA 1428/CHNY/2025[2019-20]Status: DisposedITAT Chennai20 Aug 2025AY 2019-20

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.1428/Chny/2025 Assessment Years: 2019-20 Tyspl 100 Andimadam Paccs Income Tax Officer, Limited, Ward-1, Udiyarpalayam, Ariyalur, Kumbakonam. Perambalur, Tamil Nadu-621 801. [Pan: Aacat7731L] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : G.Reddi Prakash, C.A प्रत्यर्थी की ओर से /Revenue By : Mr.Krishna Kumar Jcit सुनवाई की तारीख/Date Of Hearing : 18.08.2025 घोषणा की तारीख /Date Of Pronouncement : 20.08.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: G.Reddi Prakash, C.AFor Respondent: Mr.Krishna Kumar JCIT
Section 147Section 148Section 148ASection 151Section 151A

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 31.03.2023 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 31.03.2023 was issued by the jurisdictional assessing officer