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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

Tricentis Gmbh, Austria vs. The Deputy Commissioner of Income-Tax

In the result, appeals are allowed, as indicated above

ITA 2705/DEL/2023[2020-21]Status: DisposedITAT Delhi06 Nov 2024AY 2020-21

Bench: BEFORESHRI SAKTIJIT DEY (Vice President), SHRI S. RIFAUR RAHMAN (Accountant Member)

Section 143(2)Section 143(3)Section 144Section 144B

dated 31st March, 2021 issued by Central Board of Direct Taxes (CBDT), assessment proceedings for a foreign company cannot fall within the purview of faceless assessment scheme prescribed under section 144B of the Act. Whereas, he submitted, notice under section 143(2) of the Act was issued by National Faceless ... Centre. Thus, he submitted, in terms with CBDT Notification, on the date of issue of notice under section 143(2) of the Act, National Faceless Assessment Centre did not have jurisdiction to initiate assessment proceedings. Thus, he submitted, the assessment orders passed in pursuance to an invalid notice issued under

Asst. Commissioner of Income Tax, Circle-2(1), Hyderabad vs. Green Park Hotels and Resorts Limited, Hydrabad

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

ITA 601/HYD/2024[2020-21]Status: DisposedITAT Hyderabad05 Nov 2024AY 2020-21

Bench: Shri Manjunatha G. & Shri K.Narasimha Chary

For Appellant: Shri A.V.Raghuram, ARFor Respondent: Shri B.Bala Krishna, CIT-DR
Section 142(1)Section 143(3)Section 144BSection 69

Learned Ld.AR further submitted that the assessee company could not comply promptly to the notices under section 142(1) of the Act as the faceless assessment regime during the year under consideration was in its nascent stages of implementation and therefore failure on the part of the assessee was unintentional

Ratna Kumari Koppisetty, Kakinada vs. Income-Tax Officer, Ward-1, Kakinada

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

ITA 411/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam05 Nov 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A. No. 411/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2017-18) Ratna Kumari Koppisetty V. Income Tax Officer – Ward – 1 3-11-A/3, Recharlapeta Income Tax Office, 11-11-1 3Rd Floor, Sanjivi Hospital Complex Military Colony Ramaraopeta – 533004 Kakinada, Andhra Pradesh 533001 Andhra Pradesh [Pan: Asdpk7729B] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 143(2)Section 143(3)Section 250

petition which is as under: - “1. That for the assessment year 2017-18 an appeal has been filed before the CIT(Appeals), National Faceless Assessment Centre through a consultant at Kakinada. 2. That all the notices for hearing have been sent by the Ld.CIT(Appeals) to the e mail

Simhadri Naidu Samanthula, Palakonda vs. Income Tax Officer - Ward-1, Srikakulam

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

ITA 410/VIZ/2024[2015-16]Status: DisposedITAT Visakhapatnam05 Nov 2024AY 2015-16

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.410/Viz/2024 (िनधा"रण वष" / Assessment Year : 2015-16) Simhadri Naidu Samanthula, Vs. Income Tax Officer, Palakonda. Ward-1, Pan: Amsps2903C Srikakulam. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri I. Kama Sastry, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar सुनवाई क" तारीख / Date Of Hearing : 04/11/2024 घोषणा क" तारीख/Date Of : 05/11/2024 Pronouncement O R D E R

For Appellant: Sri I. Kama Sastry, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 149(1)Section 149(1)(b)Section 271(1)(c)Section 69A

Tribunal by raising the following modified grounds of appeal: “1. The order passed U/s. 147 r.w.s 144B by the Assessment unit, IT Department, National Faceless Assessment Centre is null and void as the assessment made is based on notice U/s. 148 which is barred by limitation as per the first ... Ward-1, Srikakulam is invalid for the reason that (i) the notice has been issued by the jurisdictional AO instead of by the National Faceless Assessment Centre as mandated by the e-assessment of income escaping assessment scheme. (ii) The notice is issued with prior approval of Pr. CCIT

Amitabha Sanyal, Kolkata vs. ITO, Ward-58(4), Kolkata

In the result, the appeal of the assessee is partly allowed and the penalty levied is hereby deleted

ITA 359/KOL/2022[2011-2012]Status: DisposedITAT Kolkata05 Nov 2024AY 2011-2012

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishraassessment Years: 2011-12 Amitabha Sanyal, Income Tax Officer, 108B, Block-F, New Alipore, Ward – 58(4), Kolkata, Kolkata – 700053 Vs Aayakar Bhawan, (Pan: Aleps2352J) Bamboo Villa, 169, A.J.C. Bose Road, Kolkata - 700014 (Appellant) (Respondent)

For Appellant: Shri Amitabha Sanyal, AssesseeFor Respondent: Shri P.P. Barman, CIT, Sr. DR
Section 139(1)Section 148Section 250Section 254(2)Section 271Section 271(1)(c)Section 275

appeal raised by the assessee are reproduced as under: “1. That the impugned order dated 11th April 2022 passed by the Ld. National Faceless Assessment Centre, Kolkata (the Assessing Officer) under section 271(1)(c) of the Act, levying penalty of Rs. 4,56,362 is without jurisdiction, illegal, invalid

Arihant Associates, Mumbai vs. ACIT Circle 30(1), Mumbai

ITA 702/MUM/2024[2017-18]Status: DisposedITAT Mumbai05 Nov 2024AY 2017-18

Bench: Shriamarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri Ruturaj GurjarFor Respondent: Shri Ram Krishna Kedia
Section 142(1)Section 143(2)Section 143(3)Section 250Section 43C

learned CIT(A)”], for the assessment year 2017-18. 2. In this appeal, the assessee has raised the following grounds: - Arihant Associates “1. National Faceless Assessment Unit (NFAC) has erred in upholding the disallowance of Rs. 50,15,000/- u/s 43CA regarding flat No. C-1103. Without appreciating following facts

Subhash Hiralal Sanchati, Surat vs. ITO, WD 1(2), Jaipur

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

ITA 591/JPR/2024[2013-14]Status: DisposedITAT Jaipur30 Oct 2024AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Parth Patni (C.A) (V.C.)For Respondent: Srhi Anup Singh (Addl. CIT)
Section 132(4)Section 144BSection 147Section 68

order dated 11.03.2022 passed under section 147 read with section 144B of the Income Tax Act, 1961 (here in after “ Act”), by the National Faceless Assessment Centre, Delhi. 2 Subhash Hiralal Sanchati. 2. The assessee has raised the following grounds: - “Ground 1 On the fact and in the circumstance

Geeta Sharma, Sunam vs. Principal Commissioner of Income Tax, Patiala

ITA 476/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh29 Oct 2024AY 2019-20

Bench: SHRI VIKRAM SINGH YADAV (Accountant Member), SHRI PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Rajiv Saldi, CAFor Respondent: ShriRohit Sharma, CIT DR
Section 10(37)Section 142(1)Section 143(2)Section 253Section 263Section 44ASection 80T

notice vide DIN & Notice No ITBA/AST/F/143(3)(SCN)/20 21-22/1035081559(1) Dated 25/08/2021 was issued to the assessee in e-portal of faceless assessment giving opportunity to explain as to why the assessment be not completed ex-parte under sec. 144 of the Income

Surendra Sampatraj Surana, Mumbai vs. Commissioner of Income Tax (Appeals), NFAC, Mumbai

In the result, the appeal is allowed for statistical purposes

ITA 4603/MUM/2024[2020-21]Status: DisposedITAT Mumbai29 Oct 2024AY 2020-21

Bench: Smt. Beena Pillai & Shri Prabhash Shankarassessment Year: 2020-21

For Appellant: Shri Ashwin DharweFor Respondent: Shri Bhangepatil P.Ramesh,Sr.DR
Section 143(3)Section 56Section 57

appellant is against the assessment order u/s. 143(3) r.w.s. 144B of the IT Act, 1961 dated 21.09.2022 passed by the National Faceless Assessment Centre, Delhi. However, the grounds of appeal raised by the appellant are with regard to order dated 11.03.2022 passed by the Asst. Commissioner. CGST and Central

Ghanshyambhai Ambalal Patel, Kheda vs. The PCIT-1, Ahmedabad

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

ITA 1007/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad28 Oct 2024AY 2014-15

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Makarand V. Mahadeokar (Accountant Member)

For Appellant: Shri Divyakant Parikh, A.RFor Respondent: Shri Prothviraj Meena, CIT-D.R
Section 147Section 263Section 69A

cash deposit was "believed to be escaped income". This so called REASON is evident from assessment order u/s 147 dated 22.03.2022 passed by National Faceless Assessment centre as also, from para 2 of the Order u/s 263 dated 21.03.2024. 3. As is undisputed, and as concluded in para ... called order dated 22.03.2022 by National Faceless Assessment Centre considering the reply of appellant dated 16.03.2022 | Paper Book Page 35 to 121 with evidences of source of bank deposits] it is categorically stated that " Considering reply filed by the assesse, the income returned is accepted " 4. It is therefore clear

Sajid Dastagir Sayyed, Latur vs. Ward 1 Latur, Latur

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

ITA 1181/PUN/2024[2014-15]Status: DisposedITAT Pune28 Oct 2024AY 2014-15

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Nikhil PathakFor Respondent: Shri Arvind Desai
Section 69A

dated 21.01.2022 and u/s 144B(1)(xi) dated 19.02.2022 was issued to the assessee subsequent to the transfer of his case to the faceless assessment centre on 11.01.2021. A show cause notice was issued to the assessee on 24.02.2024 requiring the assessee to file his reply and informing him that

Vaidyanathan Kalaivani, Chennai vs. PCIT, Chennai

Appeal of the assessee stands dismissed

ITA 1542/CHNY/2024[2019-20]Status: DisposedITAT Chennai28 Oct 2024AY 2019-20

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R. Raghunatha

For Appellant: Shri. A.S. Sriraman, AdvocateFor Respondent: Shri. Niay Baran Som, IRS, CIT
Section 142(1)Section 143(3)Section 2Section 263Section 56(2)

Rs.3,00,00,000/- is taxable as Income from Other sources and needs to be brought to tax. 4. However, the Faceless Assessing Officer without verifying the provisions of law and facts has failed to bring the amount of Rs.3,00,00,000/- to tax. Thus, the order passed ... Commissioner: 2. The order of assessment sought to be revised was passed u/s 143(3) on 13.08.2021 by the Assessing Officer, National Faceless Assessment Centre, Delhi. The Assessing Officer while passing the order had issued notice u/s 143(2) dated: 31.3.2021 intimating that the assessee's case was selected

Morgan Stanley Mauritius Company Limited, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-Circle 3(2)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3316/MUM/2023[2020-21]Status: DisposedITAT Mumbai28 Oct 2024AY 2020-21

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2020-21 Morgan Stanley Mauritius Company Dy. Cit (International Taxation) – Ltd., Circle 3(2)(2), Vs. C/O S R B C & Associates Llp, 14Th 16Th Floor, Room No. 1615, Air India Floor, The Ruby, 29, Senapati Bapat Building Nariman Point, Marg, Dadar (West), Mumbai-400021. Mumbai-400028. Pan No. Aadcm 5927 G Appellant Respondent

For Appellant: Mr. Sunil Moti LalaFor Respondent: Ms. Somogyan Pal, CIT-DR
Section 143(2)Section 143(3)Section 144C(13)Section 253

assessment proceedings is invalid as the notice was issued by the assessment proceedings is invalid as the notice was issued by the National Faceless Assessment Centre instead of the jurisdictional aceless Assessment Centre instead of the jurisdictional aceless Assessment Centre instead of the jurisdictional assessing officer, even though international taxation ... matters are assessing officer, even though international taxation matters are assessing officer, even though international taxation matters are specifically excluded from Faceless Assessment. specifically excluded from Faceless Assessment. Ground No. 2: DRP directions is bad in law as not signed by all the 3 Ground No. 2: DRP directions

Cheil India Private Limited, Gurgaon vs. Deputy Commissioner of Income Tax Circle 4(2), Delhi

In the result, appeal of the assessee is allowed

ITA 29/DEL/2024[2020-21]Status: DisposedITAT Delhi28 Oct 2024AY 2020-21

Bench: Shri Shamim Yahya & Shri Sudhir Pareeka.Yr. : 2020-21 Cheil India Private Limited Vs. Dcit, Circle 4(2), 7Th Floor, Two Horizon C.R. Building, Centre, New Delhi – 2 Golf Course Road, Gurgaon, Haryana-122001 (Pan: Aaccc2299Q) (Appellant) (Respondent)

For Appellant: Ms. Ananya Kapoor, Adv., Sh. TarunFor Respondent: Ms. Harpreet Kaur, Sr. DR
Section 115PSection 135Section 135(5)Section 143(3)Section 144BSection 250Section 270ASection 37Section 80GSection 80G(2)

Delhi dated 08.11.2023, relating to assessment year 2020-21 on the following grounds:- 1. That the assessment order dated 20.09.2022 passed by the National Faceless Assessment Centre (‘Assessment Centre’) under section 143(3) read with section 144B of the Income-tax Act, 1961 (“the Act”) and the order dated

Amazon Web Services India Private Limited, Delhi vs. Principal Commissioner of Income Tax, Delhi-1, Delhi

In the result, appeal of the assessee is allowed in the aforesaid manner

ITA 2706/DEL/2024[2018-19]Status: DisposedITAT Delhi28 Oct 2024AY 2018-19

Bench: Shri Shamim Yahya & Shri Sudhir Kumara.Yr. : 2018-19 Amazon Web Services India Vs. Principal Commissioner Of Private Limited, Income Tax, Delhi-1, Block-3, 14Th Floor, Unit Delhi Nos. 1401 To 1421, C.R. Building, I.P. Estate, New International Trade Delhi Tower, Nehru Place, New Delhi – 110 019 (Pan: Aajca9880A) (Appellant) (Respondent)

For Appellant: Shri Ajay Vohra, Sr. Adv., Ms. DeepashreeFor Respondent: Mr. Javed Akhtar, CIT(DR)
Section 143(3)Section 263Section 92C

liable to be quashed. 2. That the PCIT erred in invoking revisionary jurisdiction under section 263 of the Act qua assessment completed by National Faceless Assessment Centre (‘NFAC’) under section 143(3) r.w.s. 144C(3) and 144B of the Act, which is a complete code in itself. 3. That

Navroz Munshi, Vadodara vs. National Faceless Assessment Centre Present Jurisdiction the ITO Ward-1(2)(2), Vadodara

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

ITA 1110/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad25 Oct 2024AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.1110/Ahd/2023 िनधा"रण वष" /Assessment Year : 2017-18 Navroz Munshi National Faceless Assessment बनाम A-301, Green Emerald Centre Present / B/H. Utopian Corner Jurisdiction The Ito V/S. New Alkapuri Ward-1(2)(3) Vadodara – 390 023 Vadodara – 390 007 (Gujarat) "थायी लेखा सं./Pan: Aojpm 8149 K अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri Rushin Patel, Ar Revenue By : Shri Veerbadram Vislavath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 17/10/2024 घोषणा की तारीख /Date Of Pronouncement: 25/10/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Shri Rushin Patel, ARFor Respondent: Shri Veerbadram Vislavath, Sr.DR
Section 115BSection 142(1)Section 144Section 250Section 271ASection 69A

JUDICIAL MEMBER AND SHRI MAKARAND V. MAHADEOKAR, ACCOUNTANT MEMBER आयकर अपील सं /ITA No.1110/Ahd/2023 िनधा"रण वष" /Assessment Year : 2017-18 Navroz Munshi National Faceless Assessment बनाम A-301, Green Emerald Centre Present / B/h. Utopian Corner Jurisdiction The ITO v/s. New Alkapuri Ward-1(2)(3) Vadodara – 390 023 Vadodara

Ajd Developers Private Limited, Jaipur vs. Assistance Commissioner of Income Tax, Circle 7, Jaipur

Appeal are dismissed

ITA 536/JPR/2024[2017-18]Status: DisposedITAT Jaipur25 Oct 2024AY 2017-18

Bench: Ld. Cit(A) Against The Order Dated 26.12.2019 Passed Under Section 143(3) Of The Income Tax Act, [ For Short Act ] By The Assistant Commissioner Of Income Tax, Circle-J, Jaipur [ For Short Ao].

For Appellant: Sh. Shailesh MantriFor Respondent: Sh. Anup Singh, Addl. CIT
Section 142(1)Section 143(2)Section 143(3)Section 43CSection 44A

hands of the assessee considering the provision of section 43CA of the Act. 4. Aggrieved from the order of the National Faceless Assessment Center, assessee preferred an appeal before the ld. CIT(A). Apropos to the 4 AJD Developers Pvt. Ltd. vs. ACIT grounds so raised the relevant finding

Government Emplyees Co. Op. Credit Society Ltd., Bhavnagar vs. The ACIT, Circle-1, Bhavnagar

In the result, the appeal of the assessee is allowed

ITA 1560/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad24 Oct 2024AY 2017-18

Bench: Or At The Time Of Hearing Of An Appeal.

For Appellant: Shri Jignesh Parikh, A.RFor Respondent: Shri Nitin Vishnu Kulkarni, Sr. D.R
Section 142(1)Section 143(2)Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

ACIT ADDL/JCIT (A) Thane (for the sake of brevity "The Ld CIT(A)") erred in upholding the order of the Assessment Unit, National Faceless Assessment Centre / ACIT Circle 1, Bhavnagar (for the sake of brevity "The ld AO") passed u/s 143(3) of the Income

Vinod Jaywant, Thane vs. National Faceless Assessment Center, Faceless

In the result, appeal of the assessee is partly allowed

ITA 1712/MUM/2024[2020-2021]Status: HeardITAT Mumbai24 Oct 2024AY 2020-2021

Bench: Smt. Kavitha Rajgopal & Shri Gagan Goyalshri Vinod Jaywant, Flat No. 103, Laxmi Vilas Society, Ghantali Thane West, Maharashtra – 400 601 Pan No. Aappj5829F ..... Appellant Vs. Faceless Assessment Unit, Acit Thane (Cir 1), Maharashtra- 400 601. ..... Respondent

For Appellant: Shri Jayant Bhatt, Ld. ARFor Respondent: Ms. Rajeshwari Menon, Ld. DR
Section 133(6)Section 250

GAGAN GOYAL, ACCOUNTANT MEMBER Shri Vinod Jaywant, Flat No. 103, Laxmi Vilas Society, Ghantali Thane West, Maharashtra – 400 601 PAN No. AAPPJ5829F ..... Appellant Vs. Faceless Assessment Unit, ACIT Thane (Cir 1), Maharashtra- 400 601. ..... Respondent Appellant by : Shri Jayant Bhatt, Ld. AR Respondent by : Ms. Rajeshwari Menon, Ld. DR Date

The Society of Jesus Mary Joseph Snehalaya, Mangalagiri vs. Income-Tax Officer, Ward-2(1), Guntur

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

ITA 369/VIZ/2024[2015-16]Status: DisposedITAT Visakhapatnam23 Oct 2024AY 2015-16

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

Section 12ASection 139Section 147Section 148Section 148ASection 149(1)(b)Section 48Section 69Section 69A

Guntur is invalid for the reason that: i. The notice has been issued by the jurisdictional Assessing Officer instead of by the National Faceless Assessment Centre as mandated by the e assessment of income escaping assessment scheme. ii. The notice is issued with prior approval of Pr. CCIT, AP & Telangana ... assessee till date though the same is mandated by the CBDT guidelines for issue of notices under section 148. 4. The Assessment Unit, National Faceless Assessment Centre is not justified and the CIT(Appeals), National Faceless Appeal Centre is not justified in confirming the determination of Rs.1