“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

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

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

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

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

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

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

Mohammed Ali Abdulla, Kozhikode vs. ITO, Ward 2(2), Kozhikode

In the result, appeal of the assessee is partly allowed

ITA 47/COCH/2025[2015-16 ]Status: DisposedITAT Cochin26 Jun 2025

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm Assessment Year: 2015-16 Mohammed Ali Abdulla .......... Appellant Erivottkuni House, Payyoili Angadi, Thurayur, Kozhikode-673523. Pan: Cdfpm5769J Vs. The Income Tax Officer .......... Respondent Ward-2(2), Kozhikode. Appellant By: Shri C B M Warrier, Ca Respondent By: Smt. Leena Lal, Sr. D.R.

For Appellant: Shri C B M Warrier, CAFor Respondent: Smt. Leena Lal, Sr. D.R

Section 142(1)Section 147Section 148

that the assessee is an individual, Non- Resident Indian. No regular return of income was filed for the AY 2015-16. The National Faceless Assessment Centre, Delhi (hereinafter referred to as “AO”) based on the information that the appellant made cash deposits ie., (a) amount of Rs. 35 lakhs

DCIT, CC-1(4), Kolkata vs. Kkalpana Industries India Limited, Kolkata

In the result, appeal of the revenue is dismissed

ITA 452/KOL/2025[2016-17]Status: DisposedITAT Kolkata25 Jun 2025AY 2016-17

Bench: Shri George Mathan & Shri Sanjay Awasthiआयकर अपील सं/Ita No.452/Kol/2025 (निर्धारण वर्ा / Assessment Year : 2016-2017) Dcit, Cc-1(4), Kolkata Vs Kkalpana Industries India Ltd. 2B, Pretoria Street, Middleton Row, Kolkata-700071 Pan No. :Aabck 2239 D (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्धाररती की ओर से /Assessee By : Shri S.K.Tulsiyan, Advocate & Ms. Puja Somani, Ca रधजस्व की ओर से /Revenue By : Shri P.N.Barnwal, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 24/06/2025 घोषणा की तारीख/Date Of Pronouncement : 25/06/2025 आदेश / O R D E R Per George Mathan, Jm : This Is An Appeal Filed By The Revenue Against The Order Dated 13.11.2024, Passed By The Ld. Cit(A), Kolkata-20, Passed In Din & Order No.Itba/Apl/S/250/2024-25/1070338584(1), For The Assessment Year 2016-2017. 2. Shri P.N.Barnwal, Ld.Cit-Dr Appeared On Behalf Of The Revenue & Shri S.K.Tulsiyan, Advocate With Ms. Puja Somani, Ca, Appeared On Behalf Of The Assessee. 3. A Perusal Of The Appeal Record, We Find That The Appeal Of The Revenue Has Been Filed Belatedly By 28 Days. In This Regard, The Revenue Has Filed An Application For Condonation Of Delay Stating Sufficient Reasons Which Are Plausible & Not Found To Be False. Thus, The Delay Of 28 Days In Filing The Appeal Is Condoned & Appeal Is Admitted For Hearing.

For Appellant: Shri S.K.Tulsiyan, Advocate and Ms. Puja Somani, CAFor Respondent: Shri P.N.Barnwal, CIT-DR

Section 143(3)Section 148Section 45

assessment order is a mandatory requirement and not a procedural formality unless the order is signed assessment does not complete. 19. As per the Faceless Assessment Scheme 2019 which was substituted for e-assessment by Notification No. S.0.2745(E) dated 1 3/08/2020 w. e.f 13/08/2020 as per Clause

Arpana Jha, Bettiah vs. ITO Ward 1(5), Bettiah

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

ITA 135/PAT/2025[2017-2018]Status: DisposedITAT Patna24 Jun 2025AY 2017-2018

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 135/Pat/2025 Assessment Year: 2017-2018 Arpana Jha,……………….……….………..………Appellant C/O. Namo Nath Jha, Banuchhapar, Sant Kabir Road, Near K.P.M. School, Bihar-845438 [Pan:Ahmpj6389G] -Vs.- Income Tax Officer,……………………….…....Respondent Ward-1(5), Bettiah Appearances By: Shri Nishant Maitin, C.A., Appeared On Behalf Of The Assessee Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: June 17, 2025 Date Of Pronouncing The Order: June 24, 2025 O R D E R

Section 142(1)Section 143(2)Section 144Section 148Section 69A

dated 16/06/2021 was issued. The assessee responded to the notice on 05.08.2021. The case of the assessee was transferred to Faceless assessment on 05.08.2021and notices u/s 142(1) of the Act dated 25/11/2021 2 Arpana Jha along with questionnaire calling for various details with compliance date 10.12.2021 was issued

Dinessh Kumar Sharma, Jaipur vs. ITO, Ward4(2), Jaipur

In the result, appeal of the assessee is allowed

ITA 1393/JPR/2024[2013-14]Status: DisposedITAT Jaipur24 Jun 2025AY 2013-14

For Appellant: Shri Shivangi Chopra, C.AFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR

Section 139(1)Section 143(2)Section 144Section 147Section 148Section 250Section 69A

gross violation of principles of natural justice and thus, final assessment order was to be quashed. 6.2 Rahim Saib Hiriyur Hyder Ali vs. National Faceless Assessment Centre [2022] 145 taxmann.com 116 (Karnataka)/[2023] 291 Taxman 175 (Karnataka)/[2023] 457 ITR 253 (Karnataka)[02-09-2022] (copy annexed as Annexure

Gopal Podder, Barasat, North 24 Parganas vs. A.C.I.T., Circle - 50(1), Kolkata

Appeal of the assessee is allowed for statistical purposes

ITA 1796/KOL/2024[2017-2018]Status: DisposedITAT Kolkata24 Jun 2025AY 2017-2018

Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT SHRI SANJAY AWASTHI (Accountant Member)

Section 24Section 250Section 253Section 68

preferred by the assessee during the pendency of this appeal 7. The captioned assessment proceedings were initiated during the foundation stage of implementation of Faceless Assessment, which was genesis for every assessee as well as all professionals. Henceforth it is absolutely unaware by the assessee to communicate pursuant

Ntt India Private Limited, Mumbai vs. Asstt Comm. of Income Tax-14(1)(1), Mumbai

In the result, the appeal is accordingly partly allowed for statistical purposes

ITA 2491/MUM/2022[2018-19]Status: DisposedITAT Mumbai24 Jun 2025AY 2018-19

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhanntt India Private Vs. Assessment Unit/Nfac/Dcit Limited Circle 15(1)(2), 1701-1704, B Wing, One Mumbai Bkc, Level 17, G-Block, Aayakar Bhavan, Plot No. C-65, Bandra Mumbai. Kurla Complex, Bandra East, Mumbai-400 051. Pan/Gir No. Aaacd2145G (Applicant) (Respondent)

Section 142(1)Section 143(2)Section 143(3)Section 144CSection 271ASection 92C

assessee. Subsequently, a notice u/s 142(1) was issued to the assessee on 06.03.2020. However, in the mean time, the case was selected for Faceless assessment 3 NTT India Private Limited under the FAS, 2019 and accordingly statutory notice u/s 142(1) were issued again to the assessee

Income Tax Officer Ward 3(2)(1) Ahmedabad, Aaykar Bhawan Vejalpur Ahmedabad vs. Ramanbhai Jagabhai Bharwad, Ahmedabad

In the result, appeal of the Department is dismissed

ITA 1834/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad23 Jun 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Alpesh Parmar, CIT DRFor Respondent: Shri Tushar Hemani, Sr. Adv. & Shri

Section 148Section 149(1)(b)Section 151Section 69A

Ahmedabad, which is not in accordance with Section 151 of the Act. Moreover, the assessee submitted that as per the faceless assessment scheme under the amended Act, the notice under Section 148 should have been issued through automated allocation by the National Faceless Assessment Centre (NFAC

Raghu Satyanaryana Kollu, Kodad vs. ITO., Ward-1, Suryapet

In the result, both the captioned appeals are allowed in terms of the aforesaid observations

ITA 413/HYD/2025[2014-15]Status: DisposedITAT Hyderabad23 Jun 2025AY 2014-15

Bench: Us:

Section 147Section 148Section 250

circumstances of the case, the learned CIT (A), NFAC, Delhi erred in upholding the order passed by the learned AO, National Faceless Assessment Centre u/s 147 rws 144 & 1448 of the Act for the AY 2013-14 which is erroneous and bad in law as the additions were made

Raghu Satyanaryana Kollu, Kodad vs. ITO., Ward-1, Suryapet

In the result, both the captioned appeals are allowed in terms of the aforesaid observations

ITA 412/HYD/2025[2013-14]Status: DisposedITAT Hyderabad23 Jun 2025AY 2013-14

Bench: Us:

Section 147Section 148Section 250

Braj Kishore Singh, Andheri East vs. Assessing Officer Int. Tax Ward 4(2)(1), International Tax, Mumbai

In the result, the appeal is accordingly partly allowed for statistical

ITA 1011/MUM/2025[2015-16]Status: DisposedITAT Mumbai23 Jun 2025AY 2015-16

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhanbraj Kishore Singh Vs. Assessing Officer 604, Lantana, Nahar Amrit Internatinal Tax Ward Shakti, Chandivali, 4(2)91) Maharashtra -400 072. Room No. 632, Kautilya Bhavan, Pan: Bqips8474H C-41 To C-43, G Block, Bandra Kurla Complex, Bandra (East), Mumbai-400051

Section 142(1)Section 144C(1)Section 144C(2)Section 144C(5)Section 147Section 148Section 271(1)(c)Section 274

Ward 4(2)(1) is itself non-jurisdictional and invalid as per rules of National Faceless Assessment notification dt. 19.03.2022. Notice should be issued by FAO. 2. On the facts and circumstances of the case and law, the capital gain has to be calculated from the date of payment

Alauddin, Agra vs. ITO, Ward 1(1)(1), Agra

In the result, the appeal is partly allowed for statistical purposes

ITA 241/AGR/2024[2015-16]Status: DisposedITAT Agra20 Jun 2025AY 2015-16

Bench: : Shri Sunil Kumar Singh & Shri Manish Agarwalassessment Year: 2015-16

Section 142(1)Section 147Section 148Section 151Section 2(14)Section 250Section 54

assessee participated in the assessment proceedings, which were being proceeded in the faceless manner u/s. 144B of the Act and entire procedure of faceless assessment of income escaping assessment was adopted by the Assessing Officer as 11 | P a g e provided u/s. 151A of the Act. We accordingly

Income Tax Officer, Delhi vs. Paras Jain, Delhi

In the result, appeal of Revenue in ITA No

ITA 3554/DEL/2024[2018-19]Status: DisposedITAT Delhi20 Jun 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandrathe Income-Tax Officer Vs. Shri Paras Jain Ward – 58(7) 164-B, Gali No. - 5 Delhi Azad Nagar, East Delhi

For Appellant: Shri Ajit Gandhi, CAFor Respondent: Ms. Harpreet Kaur Hansra Sr. DR

Section 147Section 148Section 148ASection 151ASection 69Section 69C

this regard, guided by the principles of beneficial construction and thus avoiding an interpretation that would render portions of the Act or the Faceless Assessment Scheme superfluous Page 4 of 9 Shri Paras Jain (A.Y. 2018-19) or ineffective should be avoided//. To assert that the JAO's powers become ... redundant under the faceless assessment framework would conflict with beneficial construction, as it would undermine provisions specifically established to support comprehensive data analysis and informed decision-making, such as the JAO's access to RMS and Insight Portal information. 103. We are fully cognizant of the contrarian view which

Himesh Hiralal Mehta, Mumbai vs. Income Tax Officer -25(2)(4), Mumbai

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

ITA 1123/MUM/2025[2009-10]Status: DisposedITAT Mumbai19 Jun 2025AY 2009-10

Bench: Shri Om Prakash Kant () & Shri Anikesh Banerjee () Assessment Year: 2009-10 Himesh Hiralal Mehta National Faceless Assessment 3 Vallabh Niwas No 1, Centre, Delhi Ito 34(2)(1), Malavia Road, Vile Parle (East), Vs. Kautilya Bhavan, C-41, Mumbai - 40005 G Block, Bandra Kurla Complex, Bandra (East), Mumbai-400051 Pan No. Aaepm 4744 M Appellant Respondent

For Appellant: Ms. Neha ParanjpeFor Respondent: Mr. Hemanshu Joshi, CIT-DR

Section 133(6)Section 143(1)Section 148Section 69C

BENCH “E” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI ANIKESH BANERJEE (JUDICIAL MEMBER) Assessment Year: 2009-10 Himesh Hiralal Mehta National Faceless Assessment 3 Vallabh Niwas No 1, Centre, Delhi ITO 34(2)(1), Malavia Road, Vile Parle (East), Vs. Kautilya Bhavan, C-41, Mumbai

Moti Aloo Bhandar, Korba vs. Income Tax Officer-1, Korba

ITA 340/RPR/2025[2018-19]Status: DisposedITAT Raipur18 Jun 2025AY 2018-19

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 340/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19)

For Appellant: Shri G. S. Agrawal, C.AFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 147Section 148Section 148ASection 250Section 40A(3)

passed the order u/s. 148A(d) of the act on 29.03.2022 and issued notice u/s. 148 of the act. The case was transferred to Faceless Assessment Unit completion of assessment proceedings. The AO issued notice u/s. 142(1) of the act. Further, the AO issued show cause notice

Income Tax Officer Ward-1 Himatnagar, Himatnagar vs. Kalidas Jivabhai Patel, Himatnagar

In the result the appeal filed by the Revenue is dismissed and the Cross-Objection filed by the assessee is dismissed as not pressed

ITA 934/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad18 Jun 2025AY 2017-18

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.934/Ahd/2024 िनधा"रण वष" /Assessment Year : 2017-18 The Income Tax Officer, Kalidas Jivabhai Patel, Ward-1, बनाम/ Asian Parivar, V/S. Himatnagar. Nr. Mahakali Mandir Road, Himatnagar-383001. "थायी लेखा सं./Pan: Accpp5913D & C.O No.18/Ahd/2024 In आयकर अपील सं /Ita No.934/Ahd/2024 िनधा"रण वष" /Assessment Year : 2017-18 Kalidas Jivabhai Patel, The Income Tax Officer, Asian Parivar, बनाम/ Ward-1, V/S. Nr. Mahakali Mandir Road, Himatnagar. Himatnagar-383001. "थायी लेखा सं./Pan: Accpp5913D

For Appellant: Shri Vartik Chokshi with Shri Biren Shah, ARsFor Respondent: Shri Durga Dutt, CIT-DR

Section 143(1)Section 144BSection 147Section 148Section 148ASection 69

erred in upholding the validity of notice issued u/s 148 of the Act where notice was issued by Jurisdictional Assessing officer instead of Faceless Assessment Centre which is a clear violation of CBDT Notification No. 18/2022 dated 29.03.2022. The order passed u/s 147 of the Act deserves to be nullified

Mayur Dyechem Intermediates LLP, Ahmedabad vs. The Dy. CIT, Circle-3(2), Ahmedabad

In the result, Ground No. 5 of the assessee’s appeal is allowed for statistical purposes

ITA 231/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad18 Jun 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Tushar Hemani, Sr. Adv. & ShriFor Respondent: Shri Kalpesh Rupavatia, Sr. DR

Section 115BSection 143(1)Section 234BSection 270ASection 40Section 40A(2)Section 80I

perused the material on record. We observe that similar issue came before the ITAT in the case of Satia Industries Ltd. vs. National Faceless Assessment Centre, New Delhi [2023] 151 taxmann.com 358 (Amritsar - Trib.)/[2023] 106 ITR(T) 550 (Amritsar - Trib.)/[2023] 202 ITD 189 (Amritsar - Mayur Dyechem Intermediates

Jkb Exim Private Limited, New Delhi vs. DCIT Circle 13(2), New Delhi

In the result, the Appeal of the Assessee is partly allowed for

ITA 1817/DEL/2024[2017-18]Status: DisposedITAT Delhi18 Jun 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Naveen Chandrajkb Exim Private Limited Vs. Dcit 5955/3, Hardhian Singh Circle 13(2) Road, Dev Nagar, Karol C. R. Building, Ito, Ip Estate, Bagh, New Delhi New Delhi Pan: Aaccj2220J Appellant Respondent Assessee By Sh. Ajay Bhagwani, Ca & Sh. Ravinder Mahajan, C.A Revenue By Sh. Om Prakash, Sr. Dr Date Of Hearing 23/04/2025 Date Of Pronouncement 18/06/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of The Cit(A)(Appeals)/National Faceless Appeal Centre [‘Nfac’ For Short] Dated

Section 143(2)Section 143(3)Section 68

Assessee for virtual hearing in view of the ratio laid down by the Mumbai high Court in the case of Vimal Trading Vs. National Faceless Assessment in Writ Petition No. 12317/2022 dated 27/02/2025. Further direct the Ld. CIT(A) to decide the Appeal afresh in accordance with law after providing

Shila Devi, Sri Ganganagar vs. Income Tax Officer, Suratgarh

In the result, both the captioned appeals of the assesses are allowed for

ITA 242/JODH/2025[2018-19]Status: DisposedITAT Jodhpur17 Jun 2025AY 2018-19

Bench: Shri Laliet Kumar, Hon'Ble & Dr. Mitha Lal Meena, Hon'Ble

Section 144Section 144BSection 147

Union of India", [2022] 134 taxmann.com 187 (Delhi) where it was observed that Assessee would have a vested right to personal hearing in faceless assessment proceeding under section 144B and granting of personal hearing would not be discretionary as per individual facts of each case. 4. Per contra

Shri Narayan Lal Dangi, Udaipur vs. ITO, Ward-1(1), Udaipur

In the result, both the captioned appeals of the assesses are allowed for

ITA 523/JODH/2024[2010-11]Status: DisposedITAT Jodhpur17 Jun 2025AY 2010-11

Bench: Shri Laliet Kumar, Hon'Ble & Dr. Mitha Lal Meena, Hon'Ble

Section 144Section 144BSection 147

Tadikamalla Poorna Chandra Sekhara Rao, Hyderabad vs. Income-Tax Officer, Srikakkulam

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

ITA 83/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam17 Jun 2025AY 2020-21

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A. No.83/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2020-21) Tadikamalla Poorna Chandra Sekhara Rao V. Income Tax Officer 12-6-36/4/9, Flat No. 408 Palakonda Road – 532001 Andhra Pradesh Mjr Solitaire, Moosapet Balanagar, Sanathnagar Ie -530018 Telangana [Pan: Abbpt5790J] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 143(1)Section 154

treating Rs. 13,40,461/- short term capital loss as business income and levying tax on the same and the CIT(Appeals), National Faceless assessment Centre is not justified in confirming the same.” 4. When this appeal is taken up for hearing, Ld. Counsel for the assessee submitted that