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“faceless assessment scheme”

Assessment ProceduresSection 144BSection 144B332 judgments

The decision most relied on for faceless assessment scheme is Kankanala Ravindra Reddy v. ITO (156 Taxmann.com 178), cited in 213 judgments on BharatTax.

Leading authorities on faceless assessment scheme

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.

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.

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.

Sri Venkataramana Reddy v. DCIT
468 ITR 181 · 2024 · High Court
49
citing judgments

Notices under section 148 of the Income-tax Act, for international taxation charges, must be issued in a faceless manner, applying the provisions of section 144B and section 151A, in accordance with the notified scheme.

Everest Kanto Cylinder Ltd. v. DCIT/ACIT
164 Taxmann.com 608 · 2024 · High Court
24
citing judgments

Orders under section 148A(d) are subject to appeal and the Supreme Court has upheld High Court decisions that considered them appealable. The dismissal of SLPs by the Supreme Court in related cases indicates a settled position on this matter.

Patel v. Income-tax Officer
164 Taxmann.com 659 · 2024 · High Court
13
citing judgments

A notice under section 148, issued by a Jurisdictional Assessing Officer (JAO) instead of a Faceless Assessing Officer (FAO), is invalid and must be quashed as per the faceless assessment scheme under section 151A.

Judgments citing faceless assessment scheme

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 820/JPR/2025[2019-20]Status: DisposedITAT Jaipur25 Jul 2025AY 2019-20
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 143(3)Section 147

notification no.18/2022 dated 29.03.2022 issued by CBDT in terms of section 151A, para 3 of which provides that notices for assessment/re assessment/re-computation under Faceless Assessment Scheme shall be issued through "Automated Allocation, in accordance with risk management strategy formulated by the Board as referred to in section ... quashed Reliance JioInfocomm Ltd. v. Deputy Commissioner of Income-tax [2024] 165 taxmann.com 547 (Bombay) Held: As per provisions of section 151A under faceless assessment scheme notice under section 148 can be issued only by a Faceless Assessing Officer and not by a Jurisdictional Assessing Officer. Sundaram Multi

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 819/JPR/2025[2018-19]Status: DisposedITAT Jaipur25 Jul 2025AY 2018-19
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 143(3)Section 147

notification no.18/2022 dated 29.03.2022 issued by CBDT in terms of section 151A, para 3 of which provides that notices for assessment/re assessment/re-computation under Faceless Assessment Scheme shall be issued through "Automated Allocation, in accordance with risk management strategy formulated by the Board as referred to in section ... quashed Reliance JioInfocomm Ltd. v. Deputy Commissioner of Income-tax [2024] 165 taxmann.com 547 (Bombay) Held: As per provisions of section 151A under faceless assessment scheme notice under section 148 can be issued only by a Faceless Assessing Officer and not by a Jurisdictional Assessing Officer. Sundaram Multi

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 818/JPR/2025[2017-18]Status: DisposedITAT Jaipur25 Jul 2025AY 2017-18
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 143(3)Section 147

notification no.18/2022 dated 29.03.2022 issued by CBDT in terms of section 151A, para 3 of which provides that notices for assessment/re assessment/re-computation under Faceless Assessment Scheme shall be issued through "Automated Allocation, in accordance with risk management strategy formulated by the Board as referred to in section ... quashed Reliance JioInfocomm Ltd. v. Deputy Commissioner of Income-tax [2024] 165 taxmann.com 547 (Bombay) Held: As per provisions of section 151A under faceless assessment scheme notice under section 148 can be issued only by a Faceless Assessing Officer and not by a Jurisdictional Assessing Officer. Sundaram Multi

Ravinder Singh Thakkar, Jaipur vs. Assistant Commssioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 817/JPR/2025[2016-17]Status: DisposedITAT Jaipur25 Jul 2025AY 2016-17
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 143(3)Section 147

notification no.18/2022 dated 29.03.2022 issued by CBDT in terms of section 151A, para 3 of which provides that notices for assessment/re assessment/re-computation under Faceless Assessment Scheme shall be issued through "Automated Allocation, in accordance with risk management strategy formulated by the Board as referred to in section ... quashed Reliance JioInfocomm Ltd. v. Deputy Commissioner of Income-tax [2024] 165 taxmann.com 547 (Bombay) Held: As per provisions of section 151A under faceless assessment scheme notice under section 148 can be issued only by a Faceless Assessing Officer and not by a Jurisdictional Assessing Officer. Sundaram Multi

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 816/JPR/2025[2015-16]Status: DisposedITAT Jaipur25 Jul 2025AY 2015-16
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 143(3)Section 147

notification no.18/2022 dated 29.03.2022 issued by CBDT in terms of section 151A, para 3 of which provides that notices for assessment/re assessment/re-computation under Faceless Assessment Scheme shall be issued through "Automated Allocation, in accordance with risk management strategy formulated by the Board as referred to in section ... quashed Reliance JioInfocomm Ltd. v. Deputy Commissioner of Income-tax [2024] 165 taxmann.com 547 (Bombay) Held: As per provisions of section 151A under faceless assessment scheme notice under section 148 can be issued only by a Faceless Assessing Officer and not by a Jurisdictional Assessing Officer. Sundaram Multi

Samkit Shashikant Shah, Mumbai vs. Principal Commissioner of Income Tax -20, Mumbai

In the result, appeal of the assessee is allowed

ITA 3703/MUM/2025[2018-19]Status: DisposedITAT Mumbai21 Jul 2025AY 2018-19

Bench: Dropping The Reassessment Proceedings.”

Section 148Section 148ASection 148BSection 263

only allegation of the ld. PCIT in his order is that dropping of the proceedings by JAO was not in accordance with the Faceless Assessment Scheme introduced w.e.f. 13/08/2020 and therefore, dropping of assessment proceeding by JAO is erroneous and prejudicial in the interest of the Revenue. Apart from that ... under section 263 of the Act is that, prior to the allocation of the case to the Faceless Assessing Officer (FAO) under the Faceless Assessment Scheme by the DGIT (Systems), the Jurisdictional Assessing Officer (JAO), in purported contravention of the Standard Operating Procedures (SOPs), dropped the reassessment proceedings initiated under

Geethala Tejaswini, Hyderabad vs. Income Tax Officer, Ward-15(1), Hyderabad

Appeals of the assessee are allowed for statistical purposes in terms of our aforesaid observations

ITA 325/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Jul 2025AY 2014-15

Bench: Us:

Section 142(1)Section 144Section 147Section 148Section 271(1)(c)Section 68

this claim. However, the AO has mentioned in the assessment order that "Due to repeated non-responsiveness, the case was handled under the Faceless Assessment Scheme and referred to the Verification Unit for physical service of notices. A show-cause notice and a draft assessment order were issued

Geethala Tejaswini, Hyderabad vs. Income Tax Officer, Ward-15(1), Hyderabad

Appeals of the assessee are allowed for statistical purposes in terms of our aforesaid observations

ITA 324/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Jul 2025AY 2014-15

Bench: Us:

Section 142(1)Section 144Section 147Section 148Section 271(1)(c)Section 68

this claim. However, the AO has mentioned in the assessment order that "Due to repeated non-responsiveness, the case was handled under the Faceless Assessment Scheme and referred to the Verification Unit for physical service of notices. A show-cause notice and a draft assessment order were issued

Geethala Tejaswini, Hyderabad vs. Income Tax Officer, Ward-15(1), Hyderabad

Appeals of the assessee are allowed for statistical purposes in terms of our aforesaid observations

ITA 323/HYD/2025[2013-14]Status: DisposedITAT Hyderabad18 Jul 2025AY 2013-14

Bench: Us:

Section 142(1)Section 144Section 147Section 148Section 271(1)(c)Section 68

this claim. However, the AO has mentioned in the assessment order that "Due to repeated non-responsiveness, the case was handled under the Faceless Assessment Scheme and referred to the Verification Unit for physical service of notices. A show-cause notice and a draft assessment order were issued

Geethala Tejaswini, Hyderabad vs. Income Tax Officer, Ward-15(1), Hyderabad

Appeals of the assessee are allowed for statistical purposes in terms of our aforesaid observations

ITA 322/HYD/2025[2013-14]Status: DisposedITAT Hyderabad18 Jul 2025AY 2013-14

Bench: Us:

Section 142(1)Section 144Section 147Section 148Section 271(1)(c)Section 68

this claim. However, the AO has mentioned in the assessment order that "Due to repeated non-responsiveness, the case was handled under the Faceless Assessment Scheme and referred to the Verification Unit for physical service of notices. A show-cause notice and a draft assessment order were issued

Neelam Devi Gupta, Ahmedabad vs. Assessment Unit, Income Tax Department, ITO Ward-Erode

In the result, the appeal of the assessee is allowed

ITA 1310/CHNY/2025[2018-19]Status: DisposedITAT Chennai18 Jul 2025AY 2018-19

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1310/Chny/2025 Assessment Years: 2018-19 Neelam Devi Gupta, Income Tax Officer, No.J-502, Safal Parivesh, Che-W-(65)(11). Prahladnagar, Chennai. Ahmedabad, Gujarat-380 015. [Pan: Acypg4898C] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : None प्रत्यर्थी की ओर से /Revenue By : Ms.V.Supraja, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 16.07.2025 घोषणा की तारीख /Date Of Pronouncement : 18.07.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: NoneFor Respondent: Ms.V.Supraja, Addl.CIT
Section 147Section 148Section 148ASection 151Section 151ASection 68

Technologies Limited dated 03.05.2024 in WP No.1778 of 2023. The Hon’ble court's decision was , inter alia, based on the newly introduced faceless assessment scheme, established under Section 151A of the Act which mandated that reassessment notices be issued through automated allocation and in a faceless manner, thereby eliminating ... interaction between the taxpayer and the tax authorities. The court interpreted this to mean that the authority to issue reassessment notices under the faceless assessment scheme rests solely with the FAO, not the JAO. The Hon’ble Page - 5 - of 9 Bombay High Court held the view that allowing concurrent

Syed Bathrudeen Mohideen Awliya, Chennai vs. ITO, Ncw-19(6), Chennai

In the result, the appeal of the assessee is allowed

ITA 1308/CHNY/2025[2015-16]Status: DisposedITAT Chennai18 Jul 2025AY 2015-16

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1308/Chny/2025 Assessment Years: 2015-16 Syed Bathrudeen Mohideen Income Tax Officer, Awliya, Non-Corp Ward-19(6), No.8/13-C Kamaraj Nagar, Chennai. 3Rd Street, Pallavaram, Chennai-600 043. [Pan: Axrpm7549Q] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Ms.S.Sonali & Mr.S.P.Chidambaram, Advocates. प्रत्यर्थी की ओर से /Revenue By : Ms.V.Supraja, Addl.Cit

For Appellant: Ms.S.Sonali, &For Respondent: Ms.V.Supraja, Addl.CIT
Section 147Section 148Section 148ASection 151Section 151ASection 69A

Technologies Limited dated 03.05.2024 in WP No.1778 of 2023. The Hon’ble court's decision was , inter alia, based on the newly introduced faceless assessment scheme, established under Section 151A of the Act which mandated that reassessment notices be issued through automated allocation and in a faceless manner, thereby eliminating ... Page - 5 - of 9 authorities. The court interpreted this to mean that the authority to issue reassessment notices under the faceless assessment scheme rests solely with the FAO, not the JAO. The Hon’ble Bombay High Court held the view that allowing concurrent jurisdiction would lead to chaos and undermine

Amit Behal, New Delhi vs. ACIT, Circle Int. Taxation 1(1) (2), New Delhi

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

ITA 923/DEL/2024[2015-16]Status: DisposedITAT Delhi18 Jul 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Tushar Hemani, Sr. AdvFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 148Section 148ASection 69Section 69A

this regard, guided by the principles of beneficial construction and thus avoiding an interpretation that would render portions of the Act or the Faceless Assessment Scheme superfluous or ineffective should be avoided. To assert that the JAO's powers become redundant under the faceless assessment framework would conflict with beneficial

Husain Ahamed, Mumbai vs. ITO Ward, Pratapgarh

In the result, the appeal is dismissed

ITA 420/JPR/2025[2016-17]Status: DisposedITAT Jaipur04 Jul 2025AY 2016-17

Bench: SHRI MANISH BORAD (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Rakesh Kumar Kabra, CA &For Respondent: Shri Rajesh Kumar Ojha, CIT-DR
Section 144Section 147Section 148Section 69

limited to jurisdictional errors, absence of proper approval, absence of reasons for reopening, vagueness regarding the escaped income, non-compliance with the faceless assessment scheme. 4. That the order passed by ld. AO as well as by CIT(A) are bad in law 3 Husain Ahamed

Abdulzameer Hakim Khan, Mumbai vs. Income Tax Officer Ward 41(1)(1), Mumbai

In the result, both appeals by the assessee are allowed

ITA 1366/MUM/2025[2014-15]Status: DisposedITAT Mumbai03 Jul 2025AY 2014-15

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri K. GopalFor Respondent: Shri Aditya M. Rai, Sr.DR
Section 1Section 147Section 148Section 148ASection 149Section 151ASection 250Section 69A

under section 148 of the Act has been issued by the Jurisdictional Assessing Officer and hence, the same is in violation of the Faceless Assessment Scheme as provided under section 151A of the Act. Thus, the notice issued under section 148 of the Act is unlawful, invalid ... notice issued under section 148 of the Act is in contravention of the Faceless Assessment Scheme as well as the law laid down by the Hon'ble Bombay High Court in Hexaware Technologies Lid. v. ACIT (2024) 464 ITR 430 (Bombay) (03-05-2024). Hence, the notice issued under section

Abdulzameer Hakim Khan, Mumbai vs. Income Tax Officer Ward 41(1)(1), Mumbai

In the result, both appeals by the assessee are allowed

ITA 1365/MUM/2025[2013-14]Status: DisposedITAT Mumbai03 Jul 2025AY 2013-14

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri K. GopalFor Respondent: Shri Aditya M. Rai, Sr.DR
Section 1Section 147Section 148Section 148ASection 149Section 151ASection 250Section 69A

under section 148 of the Act has been issued by the Jurisdictional Assessing Officer and hence, the same is in violation of the Faceless Assessment Scheme as provided under section 151A of the Act. Thus, the notice issued under section 148 of the Act is unlawful, invalid ... notice issued under section 148 of the Act is in contravention of the Faceless Assessment Scheme as well as the law laid down by the Hon'ble Bombay High Court in Hexaware Technologies Lid. v. ACIT (2024) 464 ITR 430 (Bombay) (03-05-2024). Hence, the notice issued under section

DCIT, Mumbai vs. J Kumar Infraprojects Limited, Mumbai

The Appeal of the Assessee is partly allowed and that of the department is dismissed

ITA 4593/MUM/2024[2017-18]Status: DisposedITAT Mumbai03 Jul 2025AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

which the respected Central Board of Direct Taxes has explicitly and clearly excluded cases assigned to Central Charges from the ambit of faceless assessment scheme under Section 144B of the Act. Given that the present case was centralized with the Central Charge post-search, the requirement for issuance of notice

DCIT CC 5-1, Mumbai vs. J Kumar Infraprojects Limited, Mumbai

The Appeal of the Assessee is partly allowed and that of the department is dismissed

ITA 4591/MUM/2024[2018-19]Status: DisposedITAT Mumbai03 Jul 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

which the respected Central Board of Direct Taxes has explicitly and clearly excluded cases assigned to Central Charges from the ambit of faceless assessment scheme under Section 144B of the Act. Given that the present case was centralized with the Central Charge post-search, the requirement for issuance of notice

J Kumar Infraprojects Limited, Mumbai vs. The Dy Commissioner of Income Tax Central Circle -5(1), Mumbai

The Appeal of the Assessee is partly allowed and that of the department is dismissed

ITA 4153/MUM/2024[2020-21]Status: DisposedITAT Mumbai03 Jul 2025AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

which the respected Central Board of Direct Taxes has explicitly and clearly excluded cases assigned to Central Charges from the ambit of faceless assessment scheme under Section 144B of the Act. Given that the present case was centralized with the Central Charge post-search, the requirement for issuance of notice

J Kumar Infraprojects Limited, Mumbai vs. The Dy Commissioner of Income Tax Central Circle -5(1), Mumbai

The Appeal of the Assessee is partly allowed and that of the department is dismissed

ITA 4151/MUM/2024[2022-23]Status: DisposedITAT Mumbai03 Jul 2025AY 2022-23

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

which the respected Central Board of Direct Taxes has explicitly and clearly excluded cases assigned to Central Charges from the ambit of faceless assessment scheme under Section 144B of the Act. Given that the present case was centralized with the Central Charge post-search, the requirement for issuance of notice