“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

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

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

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

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

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

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 4150/MUM/2024[2019-20]Status: DisposedITAT Mumbai03 Jul 2025AY 2019-20

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

M/S. Rkr Graphite Private Limited, Kolkata vs. ITO Ward 12(1), Kolkata

In the result, appeal of the assessee is allowed

ITA 64/KOL/2025[2014-15]Status: DisposedITAT Kolkata30 Jun 2025AY 2014-15

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(2)Section 148Section 148ASection 68

214/Kol/2024. His further submission is that in this case assessment order has been passed by faceless AO on 29.03.2024 when the faceless assessment scheme was notified according to notice u/s 143(2) dated 03.03.2023 as well as show cause notice dated 27.02.2022 has also been issued by the faceless

Jones Lang Lasalle Property Consultants (India) Private Limited, Delhi, India vs. Deputy Commissioner of Income Tax, Circle 13(1), Delhi, India

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

ITA 3964/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jun 2025AY 2020-21

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2020-21 & Stay Application No.61/Del/2025 ( In Ita No. 3964/Del/2024 ) Assessment Year: 2020-21

For Appellant: S/Shri Nageshwar Rao and ParthFor Respondent: ShriDharam Veer Singh, CIT (DR)

Section 142(1)Section 143(2)Section 143(3)Section 144BSection 144CSection 144C(12)Section 144C(13)Section 144C(5)Section 41Section 92

such, it cannot be said that the High Court has committed any error. However, at the same time, considering the fact that the Faceless Assessment Scheme has been introduced recently and therefore, the Revenue ought to have been given some leverage to correct themselves and take corrective measures and therefore

DCIT, CC-1(4), Kolkata vs. Kkalpana Industries India Limited, Kolkata

In the result, appeal of the revenue is dismissed

ITA 452/KOL/2025[2016-17]Status: DisposedITAT Kolkata25 Jun 2025AY 2016-17

Bench: Shri George Mathan & Shri Sanjay Awasthiआयकर अपील सं/Ita No.452/Kol/2025 (निर्धारण वर्ा / Assessment Year : 2016-2017) Dcit, Cc-1(4), Kolkata Vs Kkalpana Industries India Ltd. 2B, Pretoria Street, Middleton Row, Kolkata-700071 Pan No. :Aabck 2239 D (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्धाररती की ओर से /Assessee By : Shri S.K.Tulsiyan, Advocate & Ms. Puja Somani, Ca रधजस्व की ओर से /Revenue By : Shri P.N.Barnwal, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 24/06/2025 घोषणा की तारीख/Date Of Pronouncement : 25/06/2025 आदेश / O R D E R Per George Mathan, Jm : This Is An Appeal Filed By The Revenue Against The Order Dated 13.11.2024, Passed By The Ld. Cit(A), Kolkata-20, Passed In Din & Order No.Itba/Apl/S/250/2024-25/1070338584(1), For The Assessment Year 2016-2017. 2. Shri P.N.Barnwal, Ld.Cit-Dr Appeared On Behalf Of The Revenue & Shri S.K.Tulsiyan, Advocate With Ms. Puja Somani, Ca, Appeared On Behalf Of The Assessee. 3. A Perusal Of The Appeal Record, We Find That The Appeal Of The Revenue Has Been Filed Belatedly By 28 Days. In This Regard, The Revenue Has Filed An Application For Condonation Of Delay Stating Sufficient Reasons Which Are Plausible & Not Found To Be False. Thus, The Delay Of 28 Days In Filing The Appeal Is Condoned & Appeal Is Admitted For Hearing.

For Appellant: Shri S.K.Tulsiyan, Advocate and Ms. Puja Somani, CAFor Respondent: Shri P.N.Barnwal, CIT-DR

Section 143(3)Section 148Section 45

order is a mandatory requirement and not a procedural formality unless the order is signed assessment does not complete. 19. As per the Faceless Assessment Scheme 2019 which was substituted for e-assessment by Notification No. S.0.2745(E) dated 1 3/08/2020 w. e.f 13/08/2020 as per Clause xiv, the assessment

Income Tax Officer Ward 3(2)(1) Ahmedabad, Aaykar Bhawan Vejalpur Ahmedabad vs. Ramanbhai Jagabhai Bharwad, Ahmedabad

In the result, appeal of the Department is dismissed

ITA 1834/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad23 Jun 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Alpesh Parmar, CIT DRFor Respondent: Shri Tushar Hemani, Sr. Adv. & Shri

Section 148Section 149(1)(b)Section 151Section 69A

Ahmedabad, which is not in accordance with Section 151 of the Act. Moreover, the assessee submitted that as per the faceless assessment scheme under the amended Act, the notice under Section 148 should have been issued through automated allocation by the National Faceless Assessment Centre (NFAC

Income Tax Officer, Delhi vs. Paras Jain, Delhi

In the result, appeal of Revenue in ITA No

ITA 3554/DEL/2024[2018-19]Status: DisposedITAT Delhi20 Jun 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandrathe Income-Tax Officer Vs. Shri Paras Jain Ward – 58(7) 164-B, Gali No. - 5 Delhi Azad Nagar, East Delhi

For Appellant: Shri Ajit Gandhi, CAFor Respondent: Ms. Harpreet Kaur Hansra Sr. DR

Section 147Section 148Section 148ASection 151ASection 69Section 69C

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 Page 4 of 9 Shri Paras Jain (A.Y. 2018-19) or ineffective should be avoided//. To assert that the JAO's powers become

Mumbai Metropolitan Region Development Authority, Mumbai vs. Commissioner of Income-Tax (Exemptions), Mumbai

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

ITA 2725/MUM/2024[2018-19]Status: DisposedITAT Mumbai13 Jun 2025AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV (Accountant Member), SHRI ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri Ronak DoshiFor Respondent: Shri Milind V. Patil, CIT-DR

Section 11Section 143(3)Section 144BSection 2(15)Section 263

assessing officer to carry out the same exercise and come to the same conclusion: viii) Once the assessment is carried out under the faceless assessment scheme as provided u/s. 144B of the Act, involving inter-alia, the Review Unit as a part of overall assessment procedure, non-examination and/or

Prath Krishi Sakh Sahakari Samiti Maryadit, Majhganwa vs. DCIT Circle 2(1), Jabalpur

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

ITA 150/JAB/2024[2017-18]Status: DisposedITAT Jabalpur30 May 2025AY 2017-18

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Sapan Usrethe, AdvocateFor Respondent: Sh. Alok Bhura, Sr. DR

Section 144Section 250Section 270ASection 44ASection 80P

establish that the additions made by him were not warranted in its case. We would also caution the assessee that under the new Faceless Assessment Scheme, all communications are necessarily electronic communications. Therefore, the assessee must make the necessary arrangements for receipt and reply of notices, otherwise an adverse view

Usha Marazban Pithawalla, Mumbai vs. Assessing Officer, Navi Mumbai

In the result the appeal filed by the assessee stands partly allowed for statistical purposes

ITA 2095/MUM/2025[2014-2015]Status: DisposedITAT Mumbai21 May 2025AY 2014-2015

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 144Section 144BSection 147

matted went unnoticed due to her lack of familiarity with electronic communication systems and the digital nat ure of the process under the Faceless Assessment Scheme. 4.Recently, the appellant appointed Mr. Deven Dholakia, a Chartered Ac countant, to look overher Income Tax Return work. It was through this engagement that ... husband from his NRE and NRO accounts. 6.The appellant acknowledges that due to her lack of computer knowled ge and ignorance ofthe Faceless Assessment Scheme, she failed to file the appeal within the prescribed timelimit. However, the appellant has acted promptly upon realizing the issue and is now filing

DCIT, Circle-2(1)(1), Ahmedabad vs. Navnirman Co Op. Bank Ltd, Ahmedabad

In the result, the appeal of the Revenue is hereby dismissed

ITA 1974/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad20 May 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.1974/Ahd/2024 िनधा"रण वष" /Assessment Year : 2017-18 The Dcit Navnirman Co-Op. Bank Ltd. बनाम/ Circle-2(1)(1) Navnirman Bhawan V/S. Ahmedabad – 380 015 Opp. Hdfc Bank Ahmedabad City Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aabfn 2975 L (अपीलाथ'/ Appellant) (!( यथ'/ Respondent) Assessee By : Shri Hem Chhajed, Ar Revenue By : Shri C. Dharani Nath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 13/05/2025 घोषणा की तारीख /Date Of Pronouncement: 20/05/2025

For Appellant: Shri Hem Chhajed, ARFor Respondent: Shri C. Dharani Nath, Sr.DR

Section 143(2)Section 147Section 148Section 68

party was also not provided. Assessee asked for cross-verification, which not accorded, stating that it is not possible in the faceless Assessment Scheme. Ld.AO made addition of Rs.32,49,945/- alleging that assessee bank was beneficiary of accommodation entry. Ld.AO disregarded the submission of the assessee DCIT vs. Navnirman

Kanta Devi Gupta, Jaipur vs. Income Tax Officer, Dausa

In the result, ground Nos

ITA 216/JPR/2025[2017-18]Status: DisposedITAT Jaipur08 May 2025AY 2017-18

For Appellant: Sh. K. L. Moolchandani, ITPFor Respondent: Sh. Gautam Singh Choudhary, JCIT

Section 142(1)Section 147Section 148Section 250Section 44ASection 69A

hence the consequent reassessment is also bad in law and therefore, the same may please be quashed is concerned. In my view, the faceless assessment scheme aims to enhance transparency and efficiency, there are no procedural lapses (e.g., lack of opportunity for personal hearing, non-communication of reasons for reassessment

Sunrise Realconsultancy Private Limited, Bhiwadi vs. Income Tax Officer, Ward-Bhiwadi, Bhiwadi

ITA 1308/JPR/2024[2013-14]Status: DisposedITAT Jaipur08 May 2025AY 2013-14

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

Section 142(1)Section 144Section 147Section 148Section 194HSection 271(1)(b)Section 69

file its return of income. Subsequently on 25/01/2021, the case was transferred to Regional e- Assessment Centre to complete the proceedings under Faceless Assessment Scheme, 2019. Statutory notices were issued on 01/02/2021,05/10/2021 and 09/12/2021 asking to explain the issue and submit the details called for. The assessee company neither

Sunrise Realconsultancy Private Limited, Alwar vs. Income Tax Officer, Ward-Bhiwadi, Bhiwadi

In the result, the both the appeals of the assessee are partly allowed

ITA 1307/JPR/2024[2013-24]Status: DisposedITAT Jaipur08 May 2025AY 2013-24

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

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

Section 142(1)Section 144Section 147Section 148Section 194HSection 271(1)(b)Section 69

Gck Stock Private Limited, Jaipur vs. ITO WD 1(4), Jaipur

In the result, the appeal of the assessee is partly allowed

ITA 1572/JPR/2024[2015-2016]Status: DisposedITAT Jaipur06 May 2025AY 2015-2016

For Appellant: Shri Bhupendra Shaha, C.AFor Respondent: Shri Arvind Kumar, CIT-DR

Section 131Section 133(6)Section 142(1)Section 143(3)Section 148Section 148ASection 234Section 250Section 271

Learned Authorized Representative further stated that 148A(b) notice was required to be issued by FAO as per the Faceless Assessment scheme without which order u/s.148A(d) was not tenable at all. 10. We have carefully considered the rival submissions and find that there is substantial force in the argument

Venetian Ldf Projects LLP, Gurgaon vs. ACIT Circle-4(1), Gurgaon

In the result, grounds raised by the assessee are dismissed

ITA 3533/DEL/2019[2014-15]Status: DisposedITAT Delhi01 May 2025AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 143(1)Section 143(3)Section 263Section 40A(2)

under section 263 of the Act for the reasons stated hereunder: 167 It is respectfully submitted that procedure of faceless assessment under the Faceless Assessment Scheme notified as per section 144B is a complete code in itself. The said section and the faceless assessment scheme, it is submitted, contains

Malpur Taluka Primary Teachers Sahkari Sakh & Grahak Sahkari Mandli, Malpur vs. The ACIT., Himatnagar Circle, Himatnagar

ITA 820/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2014-15

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarassessment Year 2014-15

For Appellant: Shri S. N. Divatia, A.R. &For Respondent: Smt. Mamta Singh, Sr-D.R

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 2(19)Section 250Section 80PSection 80P(2)(d)

laid down u/s I.T.A No. 820/Ahd/2023 Malpur Taluka Primery Teachers’ Sahkari Sakh & Grahak Sahkari Mandali , A.Y. 2014-15 144B read with the National Faceless Assessment Scheme which is mandatory. 1.1 The Ld. NFAC has grievously erred in law and or on facts in not considering fully & properly the written submissions

Assam Infrastructure Financing Authority, Guwahati vs. The Deputy Commissioner of Income Tax, Circle - 2 (Exemption), Kolkata

The appeal of the assessee is allowed

ITA 1223/KOL/2024[2015-16]Status: DisposedITAT Kolkata22 Apr 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. No.1223/Kol/2024 Assessment Year: 2015-16 Assam Infrastructure Financing Authority……......………………....Appellant 3Rd Floor, Block F, Finance Department, Govt. Of Assam, Assam Sachivalaya, Assam – 781006. [Pan: Aacaa9405E] Vs. Dcit, Circle-2(Exemption), Kolkata......................................…..…..... Respondent Appearances By: Shri Ramesh Goeka, Ar, Appeared On Behalf Of The Appellant. Shri S. Datta, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : April 17, 2025 Date Of Pronouncing The Order : April 22, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 31.03.2024 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. Brief Facts Of The Case Are That The Assessee Is A Society & Is Registered Under Indian Societies Act, 1860 Vide Certificate Dated 19.12.2009. The Society Was Incorporated With Cabinet Approval Of Govt. Of Assam Vide Notification No.Bw-10/2008/73 Dated 06.10.2009. The Society Is Registered U/S 12A Of The Act Vide Order For Provisional Registration Is Form 10Ac Issued By Income Tax Department On 06.04.2022 From The Period From A.Y 2022-23 To A.Y 2024-25. As Per The Memorandum Of Association, The Assessee Was Created For Implementation Of Major Infrastructure Projects In The State Of Assam.

Section 12ASection 139Section 143(2)Section 148Section 148ASection 250

total income as Nil by claiming a refund of Rs.9,29,95,166/-. The case of the assessee was later on transferred under Faceless Assessment Scheme followed by notices issued u/s 143(2) and 142(1) of the Act. In compliance to the notices, the assessee filed reply from time

Marie Products Private Limited, Jaipur vs. Assistant Commissioner of Income Tax, Circle 7, Jaipur

In the result, the appeal of the assessee is partly allowed

ITA 771/JPR/2023[2018-19]Status: DisposedITAT Jaipur21 Apr 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Sh. Ajay Malik, CIT

Section 14Section 142(1)Section 143(3)

assessment by the AQ without following the mandatory procedure laid out in the Acl As per paragraph 5(2)(xvi) of the Faceless Assessment Scheme 2021 (PB 288)/ section 1448(1)(xvi) of the Act, the AO is required to provide an opportunity to the assessee in case any variation ... procedure laid out in the Act and therefore is against the principles of natural justice. As per paragraph 5(2)(xvi) of the Faceless Assessment Scheme 2021 (PB 288)/ section 144B(1)(xvi) of the Act, the AO is required to provide an opportunity to the assessee in case

Danayya Hiremath, Near Post Office Navanagar Bagalkota vs. Income Tax Officer, Ward 1 & Tps, Bagalkot, Aayakar Bhavan

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

ITA 48/BANG/2025[2015-16]Status: DisposedITAT Bangalore21 Apr 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2015-16

For Appellant: Sri Siddesh Gaddi, A.RFor Respondent: Smt. Srinandini Das, D.R

Section 115BSection 142(1)Section 144Section 147Section 148Section 250Section 69

account/registered e-mail account on the e-filing portal of the Income tax department, and hence, the case was transferred out of the faceless assessment scheme-2021 to jurisdictional assessing officer for completion of the scrutiny proceedings. The assessee did not respond to any of the notices except a letter

Vividhodhesha Prathamika Gramina Krushi Sahakara Sangha Ni Gejjalagere, Mandya vs. Income Tax Officer, Ward-1 & Tps, Mandya

In the result appeal of the assessee is partly allowed

ITA 2071/BANG/2024[2018-19]Status: DisposedITAT Bangalore21 Apr 2025AY 2018-19

Bench: Shri Waseem Ahmedassessment Year: 2018-19

For Appellant: Shri Tarun Kothari, AdvocateFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept

Section 147Section 148Section 151Section 254Section 80P

issued under section 148 of the Act by the learned Income Tax Officer, Ward-1 & TPS, Mandya is without jurisdiction subsequent to the 'faceless assessment scheme', on the facts and circumstances of the case. c. The notice issued under section 148 of the Act in invalid for failure to strike