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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

Assistant Commissioner of Income Tax, Panchkula Circle, Panchkula vs. Estate Officer, Huda Panchkula, Panchkula

In the result, the appeals filed by the Revenue are dismissed, and the Cross Objection filed by the Assessee in those appeals are also dismissed

ITA 220/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh24 Apr 2025AY 2015-16

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri A.K. Jindal & Ms. Rattan Kaur, C.A’sFor Respondent: Shri Rohit Sharma, CIT DR (Virtual)
Section 148

served on the assessee. Thereafter notices u/s 142(1) of the Income Tax Act were issued from time to time by the Assessing Officer/National Faceless Assessment Centre which were also uploaded on the portal and not served on the assessee except the notice dated 14.02.2022, which was duly complied with ... issuance of notice u/s 148 dated 30.03.2021 by the Assessing Officer. Thereafter notices u/s 142(1) were issued on 02.11.2021 & 20.11.2021 by AO and Faceless Assessment Centre respectively which were also not served on the assessee. In the first week of February'2022, the Assessing Officer contacted the counsel

Assistant Commissioner of Income Tax, Panchkula Circle, Panchkula vs. Estate Officer, Huda Panchkula, Panchkula

In the result, the appeals filed by the Revenue are dismissed, and the Cross Objection filed by the Assessee in those appeals are also dismissed

ITA 219/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh24 Apr 2025AY 2014-15

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri A.K. Jindal & Ms. Rattan Kaur, C.A’sFor Respondent: Shri Rohit Sharma, CIT DR (Virtual)
Section 148

served on the assessee. Thereafter notices u/s 142(1) of the Income Tax Act were issued from time to time by the Assessing Officer/National Faceless Assessment Centre which were also uploaded on the portal and not served on the assessee except the notice dated 14.02.2022, which was duly complied with ... issuance of notice u/s 148 dated 30.03.2021 by the Assessing Officer. Thereafter notices u/s 142(1) were issued on 02.11.2021 & 20.11.2021 by AO and Faceless Assessment Centre respectively which were also not served on the assessee. In the first week of February'2022, the Assessing Officer contacted the counsel

Dera Sacha Sauda, Sirsa vs. PCIT(Central), Gurgaon

ITA 21/CHANDI/2024[NA]Status: DisposedITAT Chandigarh24 Apr 2025

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 21/Chd/2024 (Under Section 12Aa) M/S Dera Sacha Sauda, Shah Satnam Ji Dham, Shah Satnam Ji Marg, Sirsa. Vs The Pcit (Central), Gurgaon. स्थायी लेखा सं./Pan No: Aaatd8359H अपीलार्थी/Appellant प्रत्यर्थी/Respondent Assessee By : Shri Rakesh Gupta, Advocate & Shri Saksham Aggarwal, C.A. Revenue By : Shri Rohit Sharma, Cit,Dr Date Of Hearing 05.03.2025 Date Of Pronouncement : 25.04.2025 Per Rajpal Yadav, Vp Hybrid Hearing Order The Assessee Is In Appeal Against The Order Of Ld. Pr. Commissioner Of Income Tax, Central, Gurgaon (In Short 'The Pcit') Dated 27.12.2023 Vide Which Registration Granted Under Section 12Aa Of The Act Dated 13.12.2004 Has Been Cancelled W.E.F. 01.04.2016 By Invoking The Provisions Of Section 12Ab(4) Of The Act.

For Appellant: Shri Rakesh Gupta, Advocate andFor Respondent: Shri Rohit Sharma, CIT,DR
Section 11Section 127Section 12ASection 142Section 143(2)Section 143(3)

case of the Trust was selected for scrutiny under CASS for assessment year 2018-19 and accordingly, assessment proceedings were initiated by Faceless Assessment Unit via e-proceedings by issuance of a notice under Section 143(2) of the Act. It emerges out that case was referred

Sardarsarovar Narmada Nigam Ltd., Gandhinagar vs. The Pr. CIT, Ahmedabad-3, Ahmedabad

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

ITA 821/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad24 Apr 2025AY 2018-19

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.821/Ahd/2024 िनधा"रण वष" /Assessment Year : 2018-19 Sardarsarovar Narmada The Pr.Cit, बनाम/ Nigam Ltd. Ahmedabad-3 V/S. Block-12, 1St Floor Ahmedabad – 380 014 Near Sachivalaya Complex Gandhiangar -382 010 (Gujarat) "थायी लेखा सं./Pan: Aaccs 6704 L अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Ms. Arti N. Shah, Ar Revenue By : Shri Alpesh Parmar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 22/04/2025 घोषणा की तारीख /Date Of Pronouncement: 24/04/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Ms. Arti N. Shah, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 144BSection 263Section 37(1)

learned PCIT set aside the assessment order dated 27.05.2021 passed under section 143(3) read with section 144B of the Act by the National Faceless Assessment Centre ("NFAC"), Delhi, and directed the Sardarsarovar Narmada Nigam Ltd. vs. The Pr.CIT Asst. Year : 2018-19 Assessing Officer to pass a fresh assessment ... Appeal. 6. During the course of hearing before us, the learned Authorized Representative (AR) appearing on behalf of the assessee submitted that the Faceless Assessing Officer (FAO), during the course of assessment proceedings, had duly issued a notice under section 143(2) of the Act dated 22.09.2019, wherein specific information

Xl Health Corporation India Private Limited, Bengaluru vs. Assistant Commissioner of Income Tax, Circle-7(1)(1), Bangalore

The appeals of the assessee are dismissed as withdrawn

ITA 420/BANG/2022[2017-18]Status: DisposedITAT Bangalore24 Apr 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Prakash Chand Yadav

For Appellant: Shri Prathik Rath, AdvocateFor Respondent: Smt. Nandini Das, CIT(DR)(ITAT), Bengaluru
Section 143(3)

appeals are filed by XL Health Corporation India Pvt. Ltd. (the assessee/appellant) against the final assessment orders passed by the Assessing Officer, National Faceless Assessment Centre, Delhi (NFAC) / Assessment Unit, Income Tax Department [ld. AO] u/s. 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income

Anjali Neeraj Hardikar, Pune vs. PCIT (Central), Mumbai-3, Mumbai

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

ITA 2704/MUM/2024[2011-12]Status: DisposedITAT Mumbai24 Apr 2025AY 2011-12

Bench: Shri Sandeep Gosain & Shri Prabhash Shankaranjali Neeraj Hardikar Vs. Pcit (Central) E/3, Vibhawari Apartments, 1901, 19Th Floor, Air Sahwas Society, Lane No.1, India Bldg, Nariman Karve Nagar – 411052. Point, Maharashtra – 400021. Pan/Gir No. Aafph0320K (Applicant) (Respondent)

Section 142(1)Section 143(3)Section 263Section 271(1)(c)Section 274Section 80G

Following the initiation of the Faceless Penalty Scheme on 12.01 2021, the penalty proceedings reinitiated on 18.12.2019 were transferred to the National Faceless Assessment Centre (NaFAC). Subsequently, a new show cause notice was issued to the assessee on 01.01.2022. 6 Anjali Neeraj Hardikar, Mumbai 9. The assessee responded

Navratan Jewellers, Raipur vs. Income Tax Officer, Ward-4(1), Raipur

Appeal of the assessee is allowed for statistical purposes, in terms of over aforesaid observations

ITA 127/RPR/2025[2015-16]Status: DisposedITAT Raipur23 Apr 2025AY 2015-16

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 127/Rpr/2025 (िनधा"रण वष" Assessment Year: 2015-16)

For Appellant: Shri B. Subramanyam, CAFor Respondent: Shri S. L. Anuragi, CIT-DR
Section 115BSection 147Section 250Section 251(1)(a)

turn arises from the assessment order u/s 147 r.w.s. 144 r.w.s. 144B of the Act, dated 31.03.2022 passed by Income Tax Officer, National Faceless Assessment Centre, Delhi, (in short “Ld. AR”). 2 Navratan Jewellers Vs. ITO, Ward-4(1), Raipur 2. The grounds of appeal raised by the assessee ... memorandum, is to address cases where the best judgment assessments are made due to non-responsiveness to the letters/Notices issued by the Faceless Assessing Officer. In the appellant's case, this rationale is not applicable, as during the course of assessment proceedings the assessee has duly responded to the letter/notices

Liju Jose, Kottayam vs. Income Tax Officer Ward 5 Kottayam, Kottayam

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 175/COCH/2025[2017-18]Status: DisposedITAT Cochin23 Apr 2025AY 2017-18

Bench: Shri Inturi Rama Rao

For Appellant: Sri.Prasanth Srinivas, CAFor Respondent: Smt.Leena Lal, Senior AR
Section 143(3)Section 69

Hearing : 13.03.2025 Pronouncement : 23.04.2025 O R D E R This appeal filed by the assessee is directed against the order of the National Faceless Assessment Centre / Commissioner of Income- tax (Appeals) [“CIT(A)” for short] dated 24.12.2024 for the assessment years 2017-2018. 2. Brief facts of the case

The Bank Employees Cooperative Credit Society, Kozhikode vs. ITO, Ward 1(3), Kozhikode

In the result, the appeal filed by the assessee is dismissed

ITA 170/COCH/2025[2018-19]Status: DisposedITAT Cochin23 Apr 2025AY 2018-19

Bench: Shri Inturi Rama Rao

For Appellant: --- None ---For Respondent: Smt.Leena Lal, Senior AR
Section 139(1)Section 143(3)Section 80P

Hearing : 13.03.2025 Pronouncement : 23.04.2025 O R D E R This appeal filed by the assessee is directed against the order of the National Faceless Assessment Centre / Commissioner of Income- tax (Appeals) [“CIT(A)” for short] dated 03.08.2023 for the assessment years 2018-2019. 2. There is a delay

The Bank Employees Cooperative Credit Society, Kozhikode vs. ITO, Ward 1(3), Kozhikode

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

ITA 169/COCH/2025[2017-18]Status: DisposedITAT Cochin23 Apr 2025AY 2017-18

Bench: Shri Inturi Rama Rao

For Appellant: --- None ---For Respondent: Smt.Leena Lal, Senior AR
Section 143(3)Section 80PSection 80P(2)(d)

Hearing : 13.03.2025 Pronouncement : 23.04.2025 O R D E R This appeal filed by the assessee is directed against the order of the National Faceless Assessment Centre / Commissioner of Income- tax (Appeals) [“CIT(A)” for short] dated 29.10.2024 for the assessment years 2017-2018. 2. There is a delay

Fca India Automobiles Private Limited (Surviving Entity After the Merger of Pca Motors Pvt Ltd), Pune vs. Assessment Unit, Income Tax Department, National Faceless Assessment Centre

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

ITA 1781/PUN/2024[AY 2020-21]Status: DisposedITAT Pune23 Apr 2025

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Siddhesh ChauguleFor Respondent: Ms. Shilpa N. C
Section 10ASection 143(1)Section 143(3)Section 250Section 253Section 36(1)(va)Section 37

grounds as set out herein: 1. General ground 1.1 On the facts and circumstances of the case and in law, the National Faceless Assessment Centre ('Ld. AO') has erred in determining the total assessed income of INR 239,658,331 as against the returned income

Mukesh Kumar Bhawarlal Jain, Mumbai vs. ITO, WD 23(2)6, Mumbai

In the result, additional ground no

ITA 6745/MUM/2024[2016-17]Status: DisposedITAT Mumbai23 Apr 2025AY 2016-17
Section 144BSection 147Section 148Section 148ASection 151Section 250Section 254(1)Section 69A

valid without appreciating the fact that the said notice was issued by the Ld. Jurisdictional Assessing Officer and not by the National Faceless Assessment Centre in contravention of the faceless scheme and notification issued by the Central Board of Direct Taxes in Notification no. 18 of 2022. The appellant craves

M/S Union Bank of India, Mumbai vs. Deputy Commissioner of Incomet Tax. Circle- Ltu -2, Mumbai

In the result appeal of the assessee bearing ITA No

ITA 1678/MUM/2024[2015-16]Status: DisposedITAT Mumbai23 Apr 2025AY 2015-16

Bench: BEFOR SHRI ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri C NareshFor Respondent: ShriKrishna Kumar SR. DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 90

short, ‘the Act’), for Assessment Year 2015-16, date of order16.02.2024.The impugned order emanated from the order of the National Faceless Assessment Centre, Delhi (in short, ‘the A.O.’) date of order30/03/2022. 2. The assessee has taken the following grounds of appeal:- “Validity of assessment order 1.1 On the facts

Assam Infrastructure Financing Authority, Guwahati vs. The Deputy Commissioner of Income Tax, Circle - 2 (Exemption), Kolkata

The appeal of the assessee is allowed

ITA 1223/KOL/2024[2015-16]Status: DisposedITAT Kolkata22 Apr 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. No.1223/Kol/2024 Assessment Year: 2015-16 Assam Infrastructure Financing Authority……......………………....Appellant 3Rd Floor, Block F, Finance Department, Govt. Of Assam, Assam Sachivalaya, Assam – 781006. [Pan: Aacaa9405E] Vs. Dcit, Circle-2(Exemption), Kolkata......................................…..…..... Respondent Appearances By: Shri Ramesh Goeka, Ar, Appeared On Behalf Of The Appellant. Shri S. Datta, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : April 17, 2025 Date Of Pronouncing The Order : April 22, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 31.03.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Is A Society & Is Registered Under Indian Societies Act, 1860 Vide Certificate Dated 19.12.2009. The Society Was Incorporated With Cabinet Approval Of Govt. Of Assam Vide Notification No.Bw-10/2008/73 Dated 06.10.2009. The Society Is Registered U/S 12A Of The Act Vide Order For Provisional Registration Is Form 10Ac Issued By Income Tax Department On 06.04.2022 From The Period From A.Y 2022-23 To A.Y 2024-25. As Per The Memorandum Of Association, The Assessee Was Created For Implementation Of Major Infrastructure Projects In The State Of Assam.

Section 12ASection 139Section 143(2)Section 148Section 148ASection 250

declaring total income as Nil by claiming a refund of Rs.9,29,95,166/-. The case of the assessee was later on transferred under Faceless Assessment Scheme followed by notices issued u/s 143(2) and 142(1) of the Act. In compliance to the notices, the assessee filed reply from

Abhay Kumar Purwar Prop. Shiv Shakti Traders, Chhatarpur vs. ITO, Chhatarpur

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

ITA 240/AGR/2024[2013-14]Status: DisposedITAT Agra21 Apr 2025AY 2013-14

Bench: Shri Sunil Kumar Singh & Shri Brajesh Kumar Singh[Assessment Year: 2013-14]

Section 144Section 148Section 69C

Hearing) BEFORE SHRI SUNIL KUMAR SINGH, JUDICIAL MEMBER AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER [Assessment Year: 2013-14] Abhay Kumar Purwar Prop. National Faceless Assessment Shiv Shakti Traders, Centre, Delhi Harpalpur, Chhatarpur, Vs Madhya Pradesh-471111 PAN-ABBPP3645A Appellant Respondent Appellant by Shri Ashok Vijaywargia, CA Respondent by Shri ... order u/s 144 r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to ‘the Act’) dated 30.03.2022 passed by the National Faceless Assessment Centre, Delhi. 2. Brief facts of the case: The case was reopened vide notice u/s 148 of the Act dated 31.03.2021 after recording reasons that

Pushp Raj Bohra, Jalore vs. Pr. CIT – 1, Jodhpur

In the result, appeal filed by the Assessee is allowed

ITA 374/JODH/2024[2018-19]Status: DisposedITAT Jodhpur21 Apr 2025AY 2018-19

Bench: Dr. Mitha Lal Meena, Hon'Ble & Shri Udayan Das Gupta, Hon'Ble

Section 142(1)Section 143Section 143(2)Section 143(3)Section 263

Learned PCIT holding that the assessment order passed u/s. 143(3) read with section 143(3A) & 143(3B) of the Act by the National Faceless Assessment Centre dated 05-04-2021 as erroneous and prejudicial to the interest of the Revenue. 2. The assesse has taken the following grounds

Amarjit Singh HUF, Baghapurana, Moga vs. ITO Ward 1, Moga

In the result, the appeal of the assessee bearing ITA Nos

ITA 307/ASR/2024[2020-21]Status: DisposedITAT Amritsar21 Apr 2025AY 2020-21

Bench: Manoj Kumar Aggarwal & Sh. Udayan Das Gupta

Section 143(3)Section 144BSection 250Section 270A

That on the facts and circumstances of the case and in law, the assessment order dated 19.09.2022 passed by National Faceless Assessment Centre (“NFAC or AO”) is perverse and erroneous order, passed in violation of principles of natural justice hence, liable to be quashed. 2. That on the facts

Marie Products Private Limited, Jaipur vs. Assistant Commissioner of Income Tax, Circle 7, Jaipur

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

ITA 771/JPR/2023[2018-19]Status: DisposedITAT Jaipur21 Apr 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Sh. Ajay Malik, CIT
Section 14Section 142(1)Section 143(3)

provision of section 69C of the Act. 6 Marie Products Pvt. Ltd. vs. ACIT 3. Aggrieved from the order of the National Faceless Assessment Center, assessee preferred an appeal before the ld. CIT(A). Apropos to the grounds so raised the relevant finding of the ld. CIT(A) is reiterated ... Also, the assessment by the AQ without following the mandatory procedure laid out in the Acl As per paragraph 5(2)(xvi) of the Faceless Assessment Scheme 2021 (PB 288)/ section 1448(1)(xvi) of the Act, the AO is required to provide an opportunity to the assessee in case

M/S Gurmat Parchar Sabha (Regd.), Chandigarh vs. Nwr-W-(41)(91), Chandigarh

In the result, the appeal is allowed

ITA 1050/CHANDI/2024[2019-2020]Status: DisposedITAT Chandigarh21 Apr 2025AY 2019-2020

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

For Appellant: Shri Maninder Arora, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT Sr.DR
Section 144BSection 148Section 148ASection 151Section 151A

dated 19.01.2024 issued by Directorate of Income Tax (System). 15. From the perusal of Section 151 A. it is quite evident that scheme of faceless assessment is applicable from the stage of show cause notice under Section 148 as well as 148A. Clause 3 (b) of notification dated 29.03.2022 issued ... settled proposition of law that assessment proceedings commence from the stage of issuance of show cause notice. The object of introduction of faceless assessment would be defeated if show cause notice under Section 148 is issued by Jurisdictional Assessing Officer. The respondents arc heavily placing reliance upon office memorandum

Mandir Shri Sita Ram Ji Maharaj Sewa Samiti, Palwal vs. Income Tax Officer, National Faceless Assessment Centre, Delhi

In the result, assessee’s appeal is allowed for statistical purposes

ITA 297/DEL/2025[2019-20]Status: DisposedITAT Delhi21 Apr 2025AY 2019-20

Bench: Us That Before The Ld. First Appellate Authority Certain

Section 12ASection 144B

passed by the Ld.CIT(A)/NFAC, Delhi [DIN & Order No. ITBA/NFAC/S/250/2024-25/1070384247(1)], arising out of the order dated 28.09.2021 passed by the National Faceless Assessment Centre, under Section 144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for Assessment Year