“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

The Trivandrum Employees Co-Operative Society Limited No. 43, Thiruvananthapuram vs. The Income Tax Officer, Thiruvananthapuram

ITA 863/COCH/2023[2017-18]Status: DisposedITAT Cochin25 Sept 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri R. Krishnan, CA

Section 115BSection 144BSection 250Section 40A(3)Section 68Section 80Section 80PSection 80P(2)Section 80P(2)(d)

members who are all Govt. Employees and to merely treat huge deposits of such employees as unexplained income is absolutely against the spirit of Faceless assessment and cannons of the taxation. The Id. AO has discussed the The Trivandrum Employees Co-operative Society Ltd. reasons for addition under reference ... treating the entire deposits made by government employees in the Co- operative bank as unexplained. The assessment made is absolutely against the spirit of Faceless assessment and cannons of the taxation. Appellant prays that the order of assessment be annulled for the procedural lapses. In the altemative, the Assessing officer

The Trivandrum Employees Co-Operative Society Limited No. 43, Trivandrum vs. The Additional Joint Deputy Assistant Commissioner of Income Tax, Kochi

ITA 792/COCH/2023[2018-19]Status: DisposedITAT Cochin25 Sept 2024AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri R. Krishnan, CA

Section 115BSection 144BSection 250Section 40A(3)Section 68Section 80Section 80PSection 80P(2)Section 80P(2)(d)

Sunil J. Jagtap, Income Tax Officer(Exemptions)-1(2), Mumbai vs. Centre for the Study of Social Change, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 3941/MUM/2024[2015-16]Status: DisposedITAT Mumbai25 Sept 2024AY 2015-16

Bench: SHRI B R BASKARAN, ACCOUNTANT MEMBER, SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 11Section 12ASection 13(3)Section 14Section 143(3)Section 250Section 263

order is awaited as on date. In response to the order of the learned CIT(Exemptions)- Mumbai, the learned CIT(A), National Faceless Assessment Centre, issued notices to the assessee from time to time that were duly responded to. During the course of the assessment proceeding, a show cause notice ... which the assessee filed a very detailed submission in response. At the outset, it was pointed out to the learned CIT(A), National Faceless Assessment Centre that the proposed additions of Rs. 18,61,409/- and 4,80,00,000/- were exceeding the jurisdiction as the said issues were

Sunil J. Jagtap, Income Tax Officer (Exemptions)-1(2), Mumbai vs. Centre for the Study of Social Change, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 3940/MUM/2024[2016-17]Status: DisposedITAT Mumbai25 Sept 2024AY 2016-17

Section 11Section 12ASection 13(3)Section 14Section 143(3)Section 250Section 263

Anju Chirania, Mumbai vs. The Income Tax Officer, Ward - 4(1)(3), Mumbai

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

ITA 3158/MUM/2024[2015-16]Status: DisposedITAT Mumbai25 Sept 2024AY 2015-16

Bench: Shri Pavan Kumar Gadale, Judicialmember & Shri Girish Agrawalanju Chirania, Vs. Ito, Ward –4(1)(3), 301, Sona Chambers, Room No. 637, 507/509, Jss Road, Aayakar Bhavan, Chira Bazar, Marine Lines, M.K.Road, Mumbai – 400 002. Mumbai-400020. Pan/Gir No. Afcpc9073Q (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 133(6)Section 147Section 148Section 69A

taxmann.com 172 (Mumbai). i. Decision of Hon'ble Hon'ble ITAT, Mumbai in the case of M/s Aadesh Commodities P Limited vs National Faceless Assessment Centre, Delhi for AY 2015-16 on 24.04.2024 in ITA No. 4035/Mum/2023. j. Decision of Hon'ble Hon'ble ITAT, Mumbai in the case

Sir Ratan Tata Trust, Mumbai Suburban vs. Deputy Commissioner of Income Tax (Exemption)-2(1), Mumbai

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

ITA 1222/MUM/2024[2016-17]Status: DisposedITAT Mumbai24 Sept 2024AY 2016-17

Bench: Ms. Kavitha Rajagopal, Jm & Shri Girish Agrawal, Am Sir Ratan Tata Trust Dy. Cit(Exemption) – 2(1) Bombay House, 24, Homi Mody Street, Mtnl Tele Bulding, Cumballa Hill, Vs. Fort, Mumbai-400 001 Peddar Road, Mumbai-400 026

For Appellant: Shri Aatul SuraiyaFor Respondent: Smt. Sanyogita Nagpal

Section 11Section 11(5)Section 12ASection 13(1)(c)Section 13(1)(d)Section 13(2)(h)Section 143(1)Section 143(3)Section 144Section 144B

erred in not following the procedure as laid down in section 144B of the Act covering faceless assessment cases. 6. Without prejudice to the above, the Ld CIT(A) erred in upholding the denial of exemption under section l1 of the Act on the alleged violation of section

Siddhayu Aaurvedic Research Foundation Pvt. Ltd, Mumbai vs. Addl/Jt/ACIT/ITO/NFAC/// the ACIT Circle 34(3) (2), Delhi

In the result this appeal is dismissed with costs

ITA 745/MUM/2022[2017-18]Status: DisposedITAT Mumbai24 Sept 2024AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Gagan Goyalsiddhayu Aayurvedic Research Foundation Pvt. Ltd., C/704, Pramukh Plaza, Cardinal Gracious Road, Chakala, Andheri East, Mumbai-400 069. Pan No. Aaacs8335F ..... Appellant Vs. Acit Circle 4(3) (2) Aaykar Bhavan, M. K. Road, Mumbai-400 020. ..... Respondent

For Appellant: Shri Satyaprakash Singh, Ld. ARFor Respondent: Shri K. C. Selvamani, Ld. DR

Section 143(2)Section 143(3)Section 144CSection 234BSection 270ASection 271ASection 28Section 37(1)

prefer an appeal against the order dated 29 March 2022 passed by Additional/ Joint/Deputy/ Assistant Commissioner of Income Tax/ Income-tax Officer, National Faceless Assessment Centre, Delhi ('AO') in pursuance of the directions issued by Dispute Resolution Panel - I ('DRP'), Mumbai on the following grounds: On the facts

Subrata Das, Kolkata vs. I.T.O., Ward - 44(2), Kolkata

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

ITA 1462/KOL/2024[2018-2019]Status: DisposedITAT Kolkata23 Sept 2024AY 2018-2019

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.1462/Kol/2024 Assessment Year: 2018-19 Subrata Das………………..…….…....…………….......…....………....Appellant P-347, Cit Road, Scheme Vim Kankurgachi, Kolkata – 700054. [Pan: Acxpd9375L] Vs. Ito, Ward-44(2), Kolkata.......................................................…..…..... Respondent Appearances By: Shri Amit Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri P. P. Barman, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 23, 2024 Date Of Pronouncing The Order : September 23, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 24.06.2024 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. The Assessee In This Appeal Has Taken The Following Grounds Of Appeal: “1. That The Learned National Faceless Appeal Centre, Delhi Erred In Passing Ex-Parte Order Dated 24Th June, 2024 Under Section 250 Of The Income Tax Act, 1961 Dismissing The Appeal Of The Appellant In-Liminie Without Dealing With The Merits Of The Case & By Not Passing Speaking Order On The Grounds Of Appeal Raised By The Appellant Assessee Against The Impugned Assessment Order Dated 30.03.2021 Passed By The Ld. National Faceless Assessment Centre, Delhi (The Assessing Officer) Under Section 143(3) Of The Income Tax Act, 1961, In The Case Of The Assessee For The Assessment Year 2018-19. I.T.A. No.1462/Kol/2024 Assessment Year: 2018-19 Subrata Das

Section 143(3)Section 250Section 56(2)(x)

speaking order on the grounds of appeal raised by the Appellant Assessee against the impugned assessment order dated 30.03.2021 passed by the Ld. National Faceless Assessment Centre, Delhi (the Assessing Officer) under section 143(3) of the Income Tax Act, 1961, in the case of the Assessee for the Assessment

Ramita Shah, Mumbai vs. ACIT, Churchgate

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

ITA 3591/MUM/2024[2018-19]Status: DisposedITAT Mumbai17 Sept 2024AY 2018-19

Bench: Shri B.R. Baskaran & Ms. Kavitha Rajagopal: A.Y : 2018-19

For Appellant: Shri Bhupendra ShahFor Respondent: Smt. Sanyogita Nagpal

Section 69A

mean time, the assessee also filed a grievance petition dated 26.5.2022 against the assessment order passed by the AO before the Delhi Samadhan Faceless Assessment Committee reporting that the assessment should be treated as High Pitched scrutiny assessment. Consequently, the demand was stayed and the local PCCIT directed

Muhammad Taufiq Abubakr Navlakhiya, Mumbai vs. Assessing Officer, ACIT, Cir-24(1), Mumbai

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

ITA 4109/MUM/2023[2010-11]Status: DisposedITAT Mumbai17 Sept 2024AY 2010-11

Bench: Ms. Kavitha Rajagopal, Jm & Shri Girish Agrawal, Am Muhammad Taufiq Abubakr Assessing Officer, Acit Navlakhiya Circle-24(1) Room No. 617, Piramal Chamber, Room No. 617, Piramal Chamber, Vs. Morarji Mill Compound, Lalbaug, Morarji Mill Compound, Lalbaugh, Parel, Mumbai-400 012 Parel, Mumbai-400 012 Pan/Gir No.Acqpn 5792 A (Assessee) : (Respondent) Assessee By : Shri Sanjay Parikh Respondent By : Smt. Mahita Nair Date Of Hearing : 20.06.2024 Date Of Pronouncement : 17.09.2024

For Appellant: Shri Sanjay ParikhFor Respondent: Smt. Mahita Nair

Section 143(3)Section 148Section 250Section 271Section 271(1)Section 271(1)(c)

facts and in law in confirming the penalty of Rs. 6,96,551/- levied by the Additional/Joint/Deputy/Assistant Commissioner of Income Tax/Income Tax Officer, National Faceless Assessment Centre, Delhi (AO) on the appellant u/s. 271(1)( c) of Rs. 6,96,551/- without discussing the case laws relied

Pavan Kranti Nadiminti, Pm Palem vs. Income Tax Officer, Ward-4(4), Visakhapatnam

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

ITA 303/VIZ/2023[2017-18]Status: HeardITAT Visakhapatnam13 Sept 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No. 303/Viz/2023 (िनधा"रण वष" / Assessment Year: 2017-18) Pavan Kranti Nadiminti, Vs. Income Tax Officer, Visakhapatnam. Ward-4(4), Pan: Agxpn5603K Visakhapatnam. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri M. Muralidhar, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar सुनवाई क" तारीख / Date Of Hearing : 09/09/2024 घोषणा क" तारीख/Date Of : 13/09/2024 Pronouncement O R D E R

For Appellant: Sri M. Muralidhar, ARFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 129Section 133(6)Section 142(1)Section 144Section 250Section 271ASection 69A

Income tax act, 1961. 2. Ld CIT (A) of NFAC has erred in not following the prescribed procedure under the act with respect to faceless assessment proceedings u/s 144B(iii), hence impugned Assessment order is bad in eyes of the Law and hence assumed invalid Jurisdiction

Bakers Spices & Ingredients Private Limited, Coimbatore vs. DCIT, Corp Ward 1, Coimbatore

ITA 882/CHNY/2024[2016-17]Status: DisposedITAT Chennai12 Sept 2024AY 2016-17

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwal

For Appellant: Shri S.Sridhar, AdvocateFor Respondent: Ms. R.Anita, Addl. CIT

Section 139(1)Section 143(1)Section 147Section 148Section 148A

This appeal by the assessee is arising out of order No. ITBA/NFAC/S/250/2023-24/1060875538(1) dated 13.02.2024 passed by the Commissioner of Income Tax (Appeals), National Faceless Assessment Centre, Delhi. The assessment was framed by the Deputy Commissioner of Income Tax, National Faceless Assessment Centre (NFAC), Delhi, for the assessment year ... hereinafter the ‘Act’) vide order dated 26.03.2022. 2. The first issue in this appeal of the assessee is as regards to CIT(A), National Faceless Assessment Centre (NFAC) confirming action of the Assessing Officer in assuming jurisdiction u/s.147 r.w.s. 148 of the Act, as notice issued u/s.148 was time barred

Tushar Ramnath Shetty, Andheri East vs. The Imcome Tax Officer, Ward-23(3)(1), Mumbai, Piramal Chambers

In the result, the appeal by the assessee is allowed

ITA 3074/MUM/2024[2018-19]Status: DisposedITAT Mumbai12 Sept 2024AY 2018-19

Bench: Shri. Prashant Maharshi & Shri. Sandeep Singh Karhail

For Appellant: Shri Sanjay Parikh, CAFor Respondent: Shri Akhatar Hussain Ansari, Sr. DR

Section 142(1)Section 143Section 143(2)Section 143(3)Section 250Section 56(2)(x)

facts and in law in confirming the addition made by the Additional/Joint/Deputy/Assistant Commissioner of 1 Tushar Ramnath Shetty; A.Y.2018-19 Income/Income Tax Officer, National Faceless Assessment Centre, Delhi (AO) u/s. 56(2)(x) of Rs. 5,58,000/-. 2. The learned CIT(A) and the AO erred in not appreciating that

New India Retailing & Investment Ltd., Kolkata vs. D.C.I.T., Circle - 5(1), Kolkata

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

ITA 1285/KOL/2024[2018-2019]Status: DisposedITAT Kolkata11 Sept 2024AY 2018-2019

Bench: Sri Sonjoy Sarma & Sri Sanjay Awasthi

Section 14A

National Faceless Appeal Centre, Delhi (“Ld. CIT(A)/NFAC”) erred in confirming the addition of Rs. 15,28,389 made by the National Faceless Assessment Centre (“Ld. AO”) under section 14A of the Income Tax Act, 1961 (“the Act”) read with Rule 8D of the Income Tax Rules

Bernhard Schulte Ship Management (India) Private Limited, Powai vs. ACIT, Mumbai

ITA 1497/MUM/2024[2023-2024]Status: DisposedITAT Mumbai11 Sept 2024AY 2023-2024

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Rahul Chaudhary, Hon’Ble

For Appellant: Shri Puthur Ramachandran VijayaraghavanFor Respondent: Shri Ashok Kumar Ambastha

Section 143(1)Section 143(1)(a)Section 143(3)Section 234BSection 43B

upholding / making the 'Adjustments in the said Intimation not envisaged u/s 143(1)(a) r.w. the first Explanation thereunder and the provisions of National Faceless Assessment Scheme, 2021. 1.2. The Learned Addl. CIT (Appeals) 2, Coimbatore has erred in law and on facts in totally ignoring the fact and settled

Ten Construction (India) Private Limited, Mumbai vs. PCIT-6, Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 2318/MUM/2024[2018-19]Status: DisposedITAT Mumbai10 Sept 2024AY 2018-19

Bench: Shri Anikesh Banerjee & Shrigirish Agrawal

For Appellant: Shri R.B. PopatFor Respondent: Shri Biswanath Das - CIT SRDR

Section 143(3)Section 144BSection 263Section 263(1)

short, ‘the Act’) for A.Y. 2018-19, dt. of order 04/03/2024. The impugned order was emanated from the order of the Ld.National Faceless Assessment Centre, Delhi (in Ten Construction (India) Private Limited short, ‘the Ld.AO’) passed under section 143(3) read with section144B, date of order 21/09/2021. 2. The assesse

Divya Agrofood Product Private Limited, Kota Rajasthan vs. DCIT, ACIT, Central Circle-2, Kota, Kota Rajasthan

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

ITA 851/JPR/2024[2013-14]Status: DisposedITAT Jaipur09 Sept 2024AY 2013-14

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri B.V. Maheshwari (C.A.)For Respondent: Shri A. S. Nehra (Addl. CIT) a

Section 143(3)Section 144BSection 147

from the order dated 17.03.2022 passed under section 147 read with section 144B of the Income Tax Act, [for short Act ] by the National Faceless Assessment Centre [ for short AO ]. 2 Divya Agrofood Product Pvt. Ltd. 2. The assessee has marched this appeal on the following grounds:- “1. That

Venkateshwara Wires Pvt. Ltd., Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result, the appeal of the assessee is allowed

ITA 322/JPR/2024[2018-19]Status: DisposedITAT Jaipur09 Sept 2024AY 2018-19

Bench: The Ld. Ao As Well As Before The Ld. Cit(A) As The Documents Submitted Was Only In Support Of Confirmations & Other Documents Already Submitted & No New Documents Were Submitted. 2. The Assessee Craves Your Indulgence To Add Amend Or Alter All Or Any Grounds Of Appeal Before Or At The Time Of Hearing.”

For Appellant: Sh. S. L. Poddar, AdvFor Respondent: Sh. Anoop Singh, Addl. CIT

Section 133(6)Section 142(1)Section 143(3)Section 68Section 801ASection 80I

treated as unexplained u/s. 68 of the Act. 4 Venkateshwara Wires Pvt. Ltd. vs. ACIT 4. 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 ... furnish copy of ITRs and bank accounts. This is so mentioned on Page 12 of the assessment order, which is quoted below :- "Further, during faceless assessment proceedings, the notices u/s 133(6) of the IT Act, 1961 were issued to entities for submission of source of unsecured loan, copy

Comparex India P.Ltd, New Delhi vs. ITO, Circle-4(2), New Delhi

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

ITA 2151/DEL/2022[2018-19]Status: DisposedITAT Delhi09 Sept 2024AY 2018-19

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

For Appellant: Shri Ajit Jain, ARFor Respondent: Shri Rajesh Kumar, CIT DR

Section 143(2)Section 143(3)Section 144C(10)Section 144C(13)Section 144C(8)Section 92CSection 92C(3)

What is covered in clause 3(a) of the Scheme is already provided in Section 144B(1) of the Act, which Section provides for faceless assessment, and covers assessment, reassessment or recomputation under Section 147 of the Act. Therefore, if Revenue’s arguments are to be accepted, there ... purpose of framing a Scheme only for clause 3(a) which is in any event already covered under faceless assessment regime in Section 144B of the Act. The argument of respondent, therefore, renders the whole Scheme redundant. An argument which renders the whole Scheme otiose cannot be accepted as correct

Ebro India Pvt.Ltd., Delhi vs. ACIT Circle-7(1), Delhi

In the result, the ground no 4 raised by the assessee is allowed

ITA 1291/DEL/2022[2018-19]Status: HeardITAT Delhi09 Sept 2024AY 2018-19

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Rajesh Kumar, CIT DR

Section 143(3)Section 144BSection 144CSection 68

illegal, bad in law and liable to be quashed. 1.3. That the impugned assessment order [including draft order passed by National Faceless Assessment Centre (NF AC) under section 144C] having been passed without allowing personal hearing (either physically or virtually), in gross violation of mandatory provisions ... stood at relevant time- prior to amendment by Financial Act, 2022] statutorily mandates the procedure to be followed by the NFAC while conducting faceless assessment, with sub-section (1) thereto clearly providing, “…..the assessment under sub-section (3) of section 143 or under section 144, in cases referred