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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

Odisha Sports Development and Promotion Company, Bhubaneswar vs. DCIT, Exemption Ward, Jeypore

In the result, all three appeals of the assessee are allowed

ITA 497/CTK/2024[2016-17]Status: DisposedITAT Cuttack08 Apr 2025AY 2016-17

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita Nos.496-498/Ctk/2024 (नििाारण वर्ा / Assessment Year : 2015-16, 2016-17 & 2017-18) Odisha Sports Development & Vs Dcit, Exemption Ward, Promotion Company, Bhubaneswar Western Stand, Kalinga Stadium Bhubaneswar, Odisha Pan No. :Aabco 9237 H (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Shri P.R.Mohanty, Advocate राजस्व की ओर से /Revenue By : Shri Sanjay Kumar, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 08/04/2025 घोषणा की तारीख/Date Of Pronouncement : 08/04/2025 आदेश / O R D E R Per Bench : These Are The Appeals Filed By The Assessee Against The Separate Orders Of The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated All Dated 30.09.2024, Passed In Itba/Nfac/S/250/2024- 25/1069244316(1), Itba/Nfac/S/250/2024-25/1069244321(1) & Itba/Nfac/S/250/2024-25/1069244327(1) For The Assessment Year 2015-2016, 2016-2017 & 2017-2018. 2. Shri P.R.Mohanty, Fca Appeared On Behalf Of The Assessee. Shri Sanjay Kumar, Ld Cit Dr Represented On Behalf Of The Revenue. 3. It Was Submitted By Ld Ar Of The Assessee That The Assessee Is A Company Promoted By The Government Of Odisha. It Was The Submission That The Company’S Accounts Were Audited By Statutory Auditors. It Was The 2

For Appellant: Shri P.R.Mohanty, AdvocateFor Respondent: Shri Sanjay Kumar, CIT-DR
Section 11(2)Section 139(1)Section 143(3)Section 263

issued which is shown at page No.31 of the paper book which reads as under :- To Additional/Joint/Deputy / Assistant Commissioner of Income Tax/Income-tax Officer, National Faceless Assessment Centre, Delhi 3 ITA No.496-498/CTK/2024 Sub Submission in reply to the letter No- ITBA/AST/F/143(3)(SCN)/2021-22/1041451762(1) dated 24/03/2022. Respected Sir In respect

Odisha Sports Development Andpromotion Company, Bhubaneswar vs. DCIT, Exemption Ward, Bhubaneswar

In the result, all three appeals of the assessee are allowed

ITA 496/CTK/2024[2015-16]Status: DisposedITAT Cuttack08 Apr 2025AY 2015-16

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita Nos.496-498/Ctk/2024 (नििाारण वर्ा / Assessment Year : 2015-16, 2016-17 & 2017-18) Odisha Sports Development & Vs Dcit, Exemption Ward, Promotion Company, Bhubaneswar Western Stand, Kalinga Stadium Bhubaneswar, Odisha Pan No. :Aabco 9237 H (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Shri P.R.Mohanty, Advocate राजस्व की ओर से /Revenue By : Shri Sanjay Kumar, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 08/04/2025 घोषणा की तारीख/Date Of Pronouncement : 08/04/2025 आदेश / O R D E R Per Bench : These Are The Appeals Filed By The Assessee Against The Separate Orders Of The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated All Dated 30.09.2024, Passed In Itba/Nfac/S/250/2024- 25/1069244316(1), Itba/Nfac/S/250/2024-25/1069244321(1) & Itba/Nfac/S/250/2024-25/1069244327(1) For The Assessment Year 2015-2016, 2016-2017 & 2017-2018. 2. Shri P.R.Mohanty, Fca Appeared On Behalf Of The Assessee. Shri Sanjay Kumar, Ld Cit Dr Represented On Behalf Of The Revenue. 3. It Was Submitted By Ld Ar Of The Assessee That The Assessee Is A Company Promoted By The Government Of Odisha. It Was The Submission That The Company’S Accounts Were Audited By Statutory Auditors. It Was The 2

For Appellant: Shri P.R.Mohanty, AdvocateFor Respondent: Shri Sanjay Kumar, CIT-DR
Section 11(2)Section 139(1)Section 143(3)Section 263

issued which is shown at page No.31 of the paper book which reads as under :- To Additional/Joint/Deputy / Assistant Commissioner of Income Tax/Income-tax Officer, National Faceless Assessment Centre, Delhi 3 ITA No.496-498/CTK/2024 Sub Submission in reply to the letter No- ITBA/AST/F/143(3)(SCN)/2021-22/1041451762(1) dated 24/03/2022. Respected Sir In respect