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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

Supriya Roy, Agartala vs. ITO, Ward-1, Agartala

ITA 101/GTY/2025[2018-19]Status: DisposedITAT Guwahati03 Feb 2026AY 2018-19

Bench: Shri George Mathan, Jm & Shri Laxmi Prasad Sahu, Am (Through : Virtual Hearing) आयकर अपील सं./Ita No.101/Gty/2025 (निर्धारण वर्ष / Assessment Year 2018-2019) Vs. Ito Ward-1, Agartala Supriya Roy, Ram Thakur Trading, Central Road, Agartala, Tripura-799001 Pan No.: Acbpr 7501 G (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) निर्धारिती की ओर से / Assessee By : Shri Sanjay Mody, Ar राजस्व की ओर से /Revenue By : Shri Santosh Karnani, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 03/02/2026 घोषणा की तारीख/Date Of Pronouncement 03/02/2026 आदेश / Order Per George Mathan, Jm: This Is An Appeal Filed By The Assessee Against The Order Of The Id. Addl./Jcit(A)-2, Chennai, Dated 13.12.2023 For The Assessment Year 2018-2019. 2. At The Time Of Hearing The Ld.Ar Drew Our Attention To Pages 9 To 16 Of The Paper Book Which Was Copy Of The Written Submission Filed. The Same Reads As Follows:- 2

For Appellant: Shri Sanjay Mody, ARFor Respondent: Shri Santosh Karnani, Sr. DR
Section 133ASection 143(3)Section 69A

therefore, the variation made in the impugned order is in gross violation of section 144B and untenable. Page 7 of 8 That the Faceless Assessment Scheme has been prescribed by section 144B of the Act. That a perusal of clauses (xiv) and (xvib) of section 144B(1) and clause

Saheed Darshan Filling Station, Ludhiana vs. Income Tax Officer (ITO), Ward 3, Khanna

In the result, appeal of the assessee is allowed and Stay Application is dismissed

ITA 1736/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh03 Feb 2026AY 2018-19

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 1736/Chd/2025 "नधा"रण वष" / Assessment Year: 2018-19 Shaheed Darshan Filling Station, The Ito, Village-Iraq, Kohara Road, Vs Ward-3, Machhiwara, So-Irak, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aarfs1129H अपीलाथ"/Appellant ""यथ"/Respondent & S.A. No. 5/Chd/2026 In आयकर अपील सं./ Ita No. 1736/Chd/2025 "नधा"रण वष" / Assessment Year: 2018-19 Shaheed Darshan Filling Station, The Ito, Village-Iraq, Kohara Road, Vs Ward-3, Machhiwara, So-Irak, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aarfs1129H अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Sifatpreet Singh, Ca & Shri Amanjot Singh, Ca Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr. Dr Date Of Hearing : 28.01.2026 Date Of Pronouncement : 03.02.2026 Physical Hearing O R D E R Per Raj Pal Yadav, Vp

For Appellant: Shri Sifatpreet Singh, CA and Shri Amanjot Singh, CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT Sr. DR
Section 249Section 253Section 3Section 5

been reopened by JAO on 30.03.2022 whereas JAO has no jurisdiction to reopen an assessment after 29.03.2022. It has to be reopened by the Faceless Assessment Unit. c) The ld.CIT (Appeals) has erred in upholding the addition of alleged unaccounted transactions of Rs.1,45,07,096/-. 3. With the assistance ... Annexure P-2), issued by the Ministry of Finance. Government of India, the impugned notice could have been issued only by way of faceless assessment. 2. In support of his afore submission, learned counsel for the petitioner places reliance on the following two judgments of this Court

Nalluru Constructions, Vijayawada vs. Income Tax Officer, Circle-1(1), Vijayawada

In the result, appeal of the Assessee is allowed

ITA 646/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam30 Jan 2026AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Omkareshwar Chidaraआ.अपी.सं /Ita No.646/Viz./2025 Assessment Year 2015-2016 Nalluru Constructions, The Income Tax Officer, Vijayawada–520 010. Circle-1(1), Andhra Pradesh. Vijayawada. Vs. State Of Andhra Pradesh Pan Aaifn5778N (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri C Subrahmanyam, Ca राज" व "ारा /Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 27.01.2026 घोषणा की तारीख/Pronouncement: 30.01.2026 आदेश/Order

For Appellant: Sri C Subrahmanyam, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 144BSection 147Section 148Section 148ASection 149(1)(b)Section 250

u/secs.148(b), 148A(d) and 148 of the Act dated 16.03.2022, 03.04.2022 and 03.04.2022 respectively, are without following the procedure as per National Faceless Assessment Scheme introduced by the Finance Act, 2021 and therefore, the notice issued by the Assessing Officer u/sec.148 of the Act is not valid. He submitted ... Ward-2(1), Vijayawada u/sec.148 of the Act dated 03.04.2022 and consequent re-assessment order are invalid because the procedure as per the National Faceless Assessment Scheme u/sec.151A of the Act has not been followed and, therefore, the same is required to be set-aside. In support of this

Vijaymala Vilas Kalokhe, Pune vs. ITO Ward-10(1), Pune

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

ITA 1666/PUN/2025[2013-14]Status: DisposedITAT Pune30 Jan 2026AY 2013-14

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1666/Pun/2025 धििाारण वर्ा / Assessment Year : 2013-14 Vijaymala Vilas Kalokhe, Ito, Ward-10(1), Pune Aditya Row House, Lane No. 2, Opp. Patel Garden, Sr. No. 8/2A, Vs. Juni Sangavi, Maharashtra-411027 Pan : Asepk8161G अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Kishor B Phadke Department By : Shri Amit Bobde Date Of Hearing : 28-01-2026 Date Of 30-01-2026 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 17.06.2025 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2013-14. 2. Briefly Stated The Facts Are That The Assessee Is An Individual. He Filed His Return Of Income For Ay 2013-14 Declaring Total Income Of Rs.2,21,050/-. The Case Of The Assessee Was Reopened U/S 147 Of The Income Tax Act, 1961 (The “Act”) After Following The Mandate Procedure As Laid Down Under The Relevant Provisions Of The Act. Accordingly, Statutory Notice U/S 142(1) Of The Act & Show Cause Letter(S) Were Issued To The Assessee From Time To Time. However, The Assessee Failed To File Any Response To The Said Notice(S) Which Constrained The Ld. Assessing Officer (“Ao”) To Pass An Ex-Parte Order U/S 144 Of The Act Based On The Material Available On Record. The Ld. Ao Proceeded To Complete The Assessment On Total Income Of Rs.2,66,70,989/-U/S 147 R.W.S. 144 Of The Act Thereby Making An Addition Of Rs.2,63,83,209/- On Account Of Undisclosed Long Term Capital Gain (Ltcg) By Observing As Under : “5.1. On-Going Through The Information Available On Record & In View Of The Order Passed U/S 148A(D) Of The Act Dated 21.07.2022, It Is Noticed That 2

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amit Bobde
Section 142(1)Section 144Section 147Section 148Section 148ASection 149(1)(b)Section 2(14)Section 2(14)(iii)Section 50C

CBDT Notification issued under section 151A of ITA, 1961, notice u/s 148 of ITA, 1961 ought to have been issued by National Faceless Assessment Center (NFAC) and not by JAO and the same has also been upheld in the recent pronouncement in case of Hexaware Technologies Limited v/s ACIT (Bombay

Laxmikant Nandkishor Toshniwal, Latur vs. ITO, Ward-1, Latur

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

ITA 1853/PUN/2024[2016-17]Status: DisposedITAT Pune30 Jan 2026AY 2016-17

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1853/Pun/2024 िनधा"रण वष" / Assessment Year : 2016-17 Laxmikant Nandkishor Vs. Ito, Ward-1, Latur. Toshniwal, Nandkishor Toshniwal, Deva Niwas, Bhagya Nagar, Nandi Stop, Latur- 413512. Pan : Agppt1081M Appellant Respondent Assessee By : Shri Shubham N. Rathi (Virtual) Revenue By : Shri Amol Khairnar Date Of Hearing 05.01.2026 : Date Of Pronouncement 30.01.2026 : आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 11.07.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2016-17. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. Non-Acceptance Of Condonation Of Delay 1.1 The Learned Commissioner Of Income Tax(Appeals) ["The Ld. Cit(A)] Has Erred In Not Condoning The Delay In Filing Of The Appeal Without Properly Considering The Cause For Delay.

For Appellant: Shri Shubham N. Rathi (Virtual)For Respondent: Shri Amol Khairnar
Section 142(1)Section 147Section 148Section 68

PREJUDICE TO ABOVE ON MERITS 3. ADDITION OF CASH DEPOSIT OF ₹ 10,53,000/- U/S 68 OF THE ACT 3.1 The Assessment Unit, National Faceless Assessment Centre ['the Ld. AO'] has erred in in making addition of 10,53,000/- u/s 68 of the Act. 3.2 On the facts

Chandini Duvvuri, Hyderabad vs. ITO, (Int Taxn)-1, Hyderabad

In the result, both the appeals filed by the assessee are allowed in terms of our aforesaid observations

ITA 1855/HYD/2025[2017-18]Status: DisposedITAT Hyderabad30 Jan 2026AY 2017-18

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1842/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Chandini Duvvuri, Vs. Ito (Int. Taxation)-1, Hyderabad. Hyderabad. Pan: Aympd9716A (Appellant) (Respondent) आ.अपी.सं /Ita No.1855/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Chandini Duvvuri, Vs. Ito (Int. Taxation)-1, Hyderabad. Hyderabad. Pan: Aympd9716A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siva Charan, Ca राज" व "ारा/Revenue By: Shri Sankar Pandi P, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 28/01/2026 घोषणा की तारीख/Date Of 30/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Respective Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-10, Hyderabad, Dated 04/09/2025 & 08/09/2025, Which In Turn Arises From The Respective Orders Passed By The Assessing Officer Under Section 147 R.W.S 144 Of The Income Tax Act, 1961 (For Short, “The Chandini Duvvuri Vs. Ito (Int. Taxn) Act”), Dated 15/05/2024 & 27/05/2025 For Ay 2016-17 & Ay 2017- 18, Respectively. As A Common Issue Is Involved In The Captioned Appeals, Therefore, The Same Are Being Taken Up & Disposed Of By Way Of A Consolidated Order. We Shall First Take Up The Appeal Filed By The Assessee For Ay 2016-17 In Ita No.1842/Hyd/2025 & The Order Therein Passed Shall Apply Mutatis Mutandis For The Purpose Of Disposing Of The Other Appeal. The Assessee Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

For Appellant: Shri Siva Charan, CAFor Respondent: Shri Sankar Pandi P, Sr. AR
Section 147Section 148Section 148ASection 151ASection 251(1)(a)Section 69

Faceless Jurisdiction of the Income Tax Authorities Scheme, 2022" and the "e-Assessment of Income Escaping Assessment Scheme, 2022", it is only the “Faceless Assessing Officer” (FAO) who can issue the notice under Section 148 of the Act and not the “Jurisdictional Assessing Officer” (JAO), and the assessments are statutorily ... that Chandini Duvvuri vs. ITO (Int. Taxn) the notice issued under section 148 must comply with the requirement of the scheme for framing of Faceless Assessment whether or not the taxpayer is an NRI/Indian Resident. Apart from that, the Ld. AR submitted that involving identical facts, the Tribunal

Chandini Duvvuri, Hyderabad vs. ITO, (Int Taxn)-1, Hyderabad

In the result, both the appeals filed by the assessee are allowed in terms of our aforesaid observations

ITA 1842/HYD/2025[2016-17]Status: DisposedITAT Hyderabad30 Jan 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1842/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Chandini Duvvuri, Vs. Ito (Int. Taxation)-1, Hyderabad. Hyderabad. Pan: Aympd9716A (Appellant) (Respondent) आ.अपी.सं /Ita No.1855/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Chandini Duvvuri, Vs. Ito (Int. Taxation)-1, Hyderabad. Hyderabad. Pan: Aympd9716A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siva Charan, Ca राज" व "ारा/Revenue By: Shri Sankar Pandi P, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 28/01/2026 घोषणा की तारीख/Date Of 30/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Respective Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-10, Hyderabad, Dated 04/09/2025 & 08/09/2025, Which In Turn Arises From The Respective Orders Passed By The Assessing Officer Under Section 147 R.W.S 144 Of The Income Tax Act, 1961 (For Short, “The Chandini Duvvuri Vs. Ito (Int. Taxn) Act”), Dated 15/05/2024 & 27/05/2025 For Ay 2016-17 & Ay 2017- 18, Respectively. As A Common Issue Is Involved In The Captioned Appeals, Therefore, The Same Are Being Taken Up & Disposed Of By Way Of A Consolidated Order. We Shall First Take Up The Appeal Filed By The Assessee For Ay 2016-17 In Ita No.1842/Hyd/2025 & The Order Therein Passed Shall Apply Mutatis Mutandis For The Purpose Of Disposing Of The Other Appeal. The Assessee Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

For Appellant: Shri Siva Charan, CAFor Respondent: Shri Sankar Pandi P, Sr. AR
Section 147Section 148Section 148ASection 151ASection 251(1)(a)Section 69

Faceless Jurisdiction of the Income Tax Authorities Scheme, 2022" and the "e-Assessment of Income Escaping Assessment Scheme, 2022", it is only the “Faceless Assessing Officer” (FAO) who can issue the notice under Section 148 of the Act and not the “Jurisdictional Assessing Officer” (JAO), and the assessments are statutorily ... that Chandini Duvvuri vs. ITO (Int. Taxn) the notice issued under section 148 must comply with the requirement of the scheme for framing of Faceless Assessment whether or not the taxpayer is an NRI/Indian Resident. Apart from that, the Ld. AR submitted that involving identical facts, the Tribunal