“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

Concentrix Catalyst Technologies Private Limited, Hyderabad vs. DCIT., Circle - 1(1), Hyderabad

ITA 963/HYD/2024[2020-21]Status: DisposedITAT Hyderabad05 Dec 2025AY 2020-21

For Appellant: Shri D Prabhakar Reddy, AdvocateFor Respondent: : Dr. Narendra Kumar Naik, CIT(DR)

Section 143(3)Section 144C(13)Section 144C(5)Section 153

आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad 'DB-B‘Bench, Hyderabad श्री रविश सूद, न्यायिक

Brahmani Developers Pvt Ltd, Rourkela vs. ACIT, Circle Rourkela, Rourkela

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

ITA 330/CTK/2024[2018-19]Status: DisposedITAT Cuttack04 Dec 2025AY 2018-19

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.330/Ctk/2024 ("नधा"रण वष" / Assessment Year : 2018-19) Brahmani Developers Pvt Ltd., K4- Vs Acit, Rourkela Circle, Rourkela 9, Civil Township, Rourkela769004 Pan No. : Aadcb 2197 H (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri P.R.Mohanty, Adv राज"व क" ओर से /Revenue By : Shri Vijaya Singh, Ld Sr Dr सुनवाई क" तार"ख / Date Of Hearing : 4 /12/2025 घोषणा क" तार"ख/Date Of Pronouncement : 4 /12/2025 आदेश / O R D E R Per Bench :

For Appellant: Shri P.R.Mohanty, AdvFor Respondent: Shri Vijaya Singh, ld Sr DR

/ITA No.330/CTK/2024 ("नधा"रण वष" / Assessment Year : 2018-19) physical form before the Jurisdictional Assessing Officer for verification as per the SOP of faceless assessment scheme, the same had also been rejected by the Faceless Assessing Officer and addition had been made. It was the submission that the assessee

Brightcom Group Limited (Formerly Known As Lycos Internet Limited), Hyderabad vs. Asst. Commissioner of Income Tax, Circle-16(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 1862/HYD/2017[2013-14]Status: DisposedITAT Hyderabad03 Dec 2025AY 2013-14

Section 145Section 92BSection 92C

notice issued u/sec.148 issued by the Jurisdictional Assessing Officer [in short "JAO" instead of Faceless Assessing Officer (in short "FAO" as per the Faceless Assessment Scheme has quashed the notice issued u/sec. 148 by the JAO and consequently, re-assessment order, but, granted the liberty to the parties

Lalit Kumar, New Delhi vs. ITO Ward-1, Panipat, Haryana

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

ITA 1626/DEL/2025[2015-16]Status: DisposedITAT Delhi03 Dec 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year 205-16] Lalit Kumar, Vs Ito, Ward -1 C/O B-50, Lgf, South Extension- Panipat, Haryana Ii, New Delhi-110049 Pan: Aczpk4479N Appellant Respondent Ms. Jahnavi Khanna, Adv. Assessee By Department By Shri Manish Gupta, Sr. Dr Date Of Hearing 16.09.2025 Date Of Pronouncement 16.09.2025 O R D E R

Section 250

assessee. 4. After considering the arguments, we find that in the instant case, the assessee was not aware of such drastic changes in faceless assessment schemes and was unware of all the activities like issue of notices through email and to respond such notices online, therefore, due compliance could

Mr. Sachiv Sahni, Mumbai vs. ACIT, CC-2(3), Mumbai

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

ITA 6070/MUM/2025[2022-23]Status: DisposedITAT Mumbai02 Dec 2025AY 2022-23

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

Section 143(3)Section 144BSection 147Section 148Section 250

complete disregard of the mandatory procedure prescribed under section 144B/ 151A of the Act. The said assessment, having been framed dehors the faceless assessment scheme and in violation of the statutory mandate, is ex facie without jurisdiction, null and void ab initio, and liable to be quashed on this ground ... complete disregard of the mandatory procedure prescribed under section 144B/ 151A of the Act. The said assessment, having been framed dehors the faceless assessment scheme and in violation of the statutory mandate, is ex facie without jurisdiction, null Mr. Sachiv Sahni,. Mumbai. and void ab initio, and liable

Mr. Sachiv Sahni, Mumbai vs. ACIT, CC-2(3), Mumbai

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

ITA 6069/MUM/2025[2021-22]Status: DisposedITAT Mumbai02 Dec 2025AY 2021-22

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

Section 143(3)Section 144BSection 147Section 148Section 250

Mr. Sachiv Sahni, Mumbai vs. ACIT, CC-2(3), Mumbai

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

ITA 6068/MUM/2025[2020-21]Status: DisposedITAT Mumbai02 Dec 2025AY 2020-21

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

Section 143(3)Section 144BSection 147Section 148Section 250

Mr. Akil Abbas Rassai, Mumbai vs. The Deputy Commissioner of Income Tax, Circle 22(1), Mumbai

The appeal of the assessee is allowed for statistical purposes

ITA 5761/MUM/2025[2018-19]Status: DisposedITAT Mumbai02 Dec 2025AY 2018-19

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Appellant: Shri Rakesh Joshi, AR

Section 142(1)Section 143(2)Section 143(3)Section 144BSection 250Section 56(2)(x)

declaring total income at Rs.36,34,300/-. This case had been selected for scrutiny under manual selection of cases category through Faceless Assessment Scheme, based on information that the appellant had purchased immovable property and that the consideration paid was lower than the market value i.e. SRO valuation. Subsequently, notices

Ubs Business Solutions (India) Private Limited (Successor to Credit Suisse Services (India) Pvt Ltd), Pune vs. PCIT, Pune - 1, Pune, Maharashtra

In the result, appeal of the Assessee is allowed

ITA 1407/PUN/2025[2020-21]Status: DisposedITAT Pune28 Nov 2025AY 2020-21

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1407/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Ubs Business Solutions (India) V The Principal Pvt. Ltd. (Successor To Credit S. Commissioner Of Suisse Services (India) Pvt Income Tax, Ltd.), Pune-1. Cluster A, Eon Free Zone, Plot No.1, S.No.77, Ground To 5Th Floors In Wing 1, 3Rd To 5Th Floor In Wing 2, Kharadi Midc Knowledge Park, Pune – 411014. Pan: Aabcu8718M Appellant/ Assessee Respondent / Revenue Assessee By Shri Rajendra Agiwal - Ar Revenue By Shri Amit Bobde – Cit(Dr) Date Of Hearing 23/09/2025 Date Of Pronouncement 28/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Principal Commissioner Of Income Tax, Pune-1 Passed Under Section 263 Of The Income Tax Act, 1961 For A.Y.2020-21, Dated 31.03.2025 Emanating From Assessment Order U/S.143(3) R.W.S 144B

Section 143(3)Section 144BSection 263Section 80G

page no. 87 to 90 of the factual paper book submitted on 02.07.2025). The appellant's case was selected for complete scrutiny under Faceless Assessment Scheme through CASS (Please refer notice U/s 143(2) dated 29.06.2021 on page no. 392 of the Paper book). The case was selected for further

Apaasso Mali, Pune vs. ITO 11(1), Swargate

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

ITA 1110/PUN/2025[2018-19]Status: DisposedITAT Pune28 Nov 2025AY 2018-19

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

For Appellant: Shri Suhas KulkarniFor Respondent: Shri A D Kulkarni

Section 142(1)Section 144Section 147Section 147rSection 148Section 249Section 249(2)

their tax matters. II. The notices were issued through the Income Tax Department's web portal, the designated mode of communication under the faceless assessment scheme. As per Section 282 of the Income Tax Act, read with Rule 127A of the Income Tax Rules, electronic communication through the portal constitutes ... claim of unawareness does not hold merit, as taxpayers have a duty to monitor their online accounts for official communications. III. The faceless assessment scheme, introduced under Section 1448 of the Income Tax Act, does not require individual intimation to taxpayers regarding the transfer of jurisdiction to the National Faceless

Sudhakar Rao Sandineni, Nalgonda vs. ITO, Ward-1, Nalgonda

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

ITA 1604/HYD/2025[2016-17]Status: DisposedITAT Hyderabad28 Nov 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri Y.V.Bhanu Narayan RaoFor Respondent: Ms. G. Saratha, SR-DR

Section 148Section 148A

appeal set. Thus he has submitted that the notice u/s.148 issued by the JAO without following the procedure as per the National Faceless Assessment Scheme / Reassessment Scheme notified by the CBDT is not valid and liable to be quashed. Thus the Ld. AR has submitted that the notice ... u/s.148 of the Act are issued by the ITO, Ward-1, Nalgonda (JAO) without following the procedure as laid down in the National Faceless Assessment Scheme / Reassessment Scheme notified by the CBDT. At the outset, we note that an identical issue has been considered by this Tribunal in the case

Brijesh Chandwani, Hyderabad vs. DCIT., Circle -6(1), Hyderabad

In the result, appeal of the assessee for the assessment year 2020-2021 is allowed for statistical purposes

ITA 1528/HYD/2025[2020-2021]Status: DisposedITAT Hyderabad28 Nov 2025AY 2020-2021

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1527 & 1528/Hyd/2025 Assessment Years – 2016-2017 & 2020-2021 Brijesh Chandwani The Dcit, Circle-6(1), Vs. Hyderabad – 500 034 Hyderabad. Pan Adkpc1537H (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Pawan Kumar Chakrapani राज" व "ारा /Revenue By: Sri Ranjan Agrawala, Sr. Ar

For Appellant: CA Pawan Kumar ChakrapaniFor Respondent: Sri Ranjan Agrawala, Sr. AR

Section 133ASection 143(1)(a)Section 143(3)Section 147Section 148Section 148ASection 234A

allowed on this ground alone. 24. Ground No.6 the assessee challenged validity of notice u/sec.148 as the same was issued without following National Faceless Assessment Scheme notified by the CBDT. 46 ITA.No.1527 & 1528/Hyd./2025 25. The learned Authorised Representative of the Assessee has submitted that the Jurisdictional Assessing Officer

Brijesh Chandwani, Hyderabad vs. DCIT., Circle -6(1), Hyderabad

The appeal of the Assessee is allowed on this ground alone

ITA 1527/HYD/2025[2016-2017]Status: DisposedITAT Hyderabad28 Nov 2025AY 2016-2017

For Appellant: CA Pawan Kumar ChakrapaniFor Respondent: Sri Ranjan Agrawala, Sr. AR

Section 133ASection 143(1)(a)Section 143(3)Section 147Section 148Section 148ASection 234A

allowed on this ground alone. 24. Ground No.6 the assessee challenged validity of notice u/sec.148 as the same was issued without following National Faceless Assessment Scheme notified by the CBDT. 25. The learned Authorised Representative of the Assessee has submitted that the Jurisdictional Assessing Officer [in short

Vinod Ojha, Hyderabad vs. Income Tax Officer, Ward-5(1), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 1231/HYD/2024[2016-17]Status: DisposedITAT Hyderabad28 Nov 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1231/Hyd/2024 (िनधा"रण वष"/Assessment Year 2016-2017) Vinod Ojha, The Income Tax Officer, Ward-5(1), Hyderabad-500012. Vs. Hyderabad – 500 057. Telangana. Telangana. Pan Aahpo3171F (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Kumar Pal Tated राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit-Dr

For Appellant: CA Kumar Pal TatedFor Respondent: Dr. Narendra Kumar Naik, CIT-DR

Section 139(1)Section 144Section 147Section 148Section 149

issued u/sec.148 of the Act on the ground that the notice was issued by the jurisdictional Assessing Officer in contravention of the National Faceless Assessment Scheme as notified by the CBDT vide Notification No.15/2022 dated 28.03.2022 and, therefore, the said notice is not valid and liable to be quashed

Mr. Jitendra Walia, Hardwar vs. ITO, W-1(3)(1) 44(2), Haridwar

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

ITA 115/DDN/2025[2015-16]Status: DisposedITAT Dehradun27 Nov 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalmr. Jitendra Walia, Income Tax Officer, 653, Sarai Road, Ward-1(3)(1), 44(2), Jwalapur, Haridwar-249407. Vs. Haridwar. Pan:Abvpw9014C (Appellant) (Respondent) Assessee By Shri Tarandeep Singh, Adv. & Shri Sandeep Yadav, Adv. Department By Shri A.S. Rana, Sr. Dr Date Of Hearing 11.09.2025 Date Of Pronouncement 27.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (‘The Cit(A) In Short) Passed U/S 250 Of The Income Tax Act, 1961, Dated 22.04.2025 For Assessment Year 2015-16. 2. At The Outset, It Is Seen That The Appeal Of The Assessee Is Dismissed By The Ld. Cit(A) For Non-Prosecution. Before Us, The Ld. Ar Submitted That The Ld. Cit(A) Has Issued Notices Which Were Delivered To The Registered Email Address Of The Appellant & Were Also Uploaded In The Portal Of The Department, However, The Assessee Was Not Aware Of The Proceedings Nor Such Notices Were Brought To His Knowledge By The Accountant Of The Assessee, Therefore, The Necessary Compliance Could Not Be Made Either Before The Ao Or Before The Cit(A). He Thus

Section 250

Epam Systems India Private Limited, Hyderabad vs. DCIT, Circle -8 (1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 83/HYD/2022[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: CA Shreyas SardesaiFor Respondent: MS U Mini Chandran, CIT-DR

Section 143(3)

Epam Systems India Private Limited, Hyderabad vs. ACIT, Circle-8(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 498/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

For Appellant: CA Shreyas SardesaiFor Respondent: MS U Mini Chandran, CIT-DR

Section 143(3)

M/S Quasar India Ltd, Delhi vs. ACIT, Circle-19(1), Delhi

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

ITA 343/DEL/2025[2014-15]Status: DisposedITAT Delhi26 Nov 2025AY 2014-15

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2014-15 M/S. Quasar India Limited, Vs. Assessment Unit-Nfca, 101, First Floor, Baroda Tower, Income Tax Department, Central Market, Prashant Vihar, Acit, Circle 19(1), Rohini, Delhi-1100 85. Delhi Pan :Aaacq0219Q (Appellant) (Respondent)

Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 151Section 250

Received 20.05.2023 - - notice Video 26.05.2023 27.05.2023 Not - - - Conference attended Subsequently, the case was assigned to this office for assessment proceedings under Faceless Assessment Scheme of the department. Notices under Section 142(1) of the Act was issued to the assessed from time to time and has given full 3 opportunities

Swaminath Baburao Patil, Solapur vs. ITO Ward 2(3) Solapur, Solapur

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

ITA 832/PUN/2025[2014-2015]Status: DisposedITAT Pune25 Nov 2025AY 2014-2015

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.832/Pun/2025 निर्धारण वषा / Assessment Year: 2014-15 Swaminath Baburao Patil, V The Income Tax Officer, C37, Siddheshwar Market S Ward-2(3), Solapur. Yard, Hyderabad Road, Solapur – 431005. Maharashtra. Pan: Akwpp4321P Appellant/ Assessee Respondent / Revenue Assessee By Shri Girish Ladda Revenue By Shri Ambarnath Khule (Through Virtual Hearing) – Jcit(Dr) Date Of Hearing 24/11/2025 Date Of Pronouncement 25/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2014-15 Dated 27.01.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Act, Dated 19.05.2023. The Assessee Has Raised The Following Grounds Of Appeal :

Section 139(1)Section 143(2)Section 147Section 148Section 148ASection 151ASection 153CSection 249(4)(a)Section 250Section 292B

151A read with Notification no. 18/2022 dated 29th March 2022 mandates all such notices to be issued by the FAO under the National Faceless Assessment Scheme. Hence, it is prayed that Notice U/s 148 and consequent assessment order both may please be quashed. 6) Without prejudice to above grounds

Sujatha Hariharan, Chennai vs. ITO, Ncw-3(3), Chennai

In the result, both the appeals filed by the assessee are

ITA 2491/CHNY/2025[2015-16]Status: DisposedITAT Chennai19 Nov 2025AY 2015-16

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.: 2490 & 2491/Chny/2025 निर्धारण वर्ष/Assessment Year: 2015-16 Smt. Sujatha Hariharan, Old No.20, New No.8, Poes Road, 2Nd Street, Teynampet, Chennai - 600 018. The Income Tax Officer, Vs. Non-Corporate Ward 3(3), Chennai. Pan: Bgcps 5734A (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri Y. Sridhar, Fca प्रत्यर्थी की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 18.11.2025 घोषणा की तारीख/Date Of Pronouncement : 19.11.2025 आदेश/Order Per George George K: These Appeals Filed By The Assessee Are Directed Against Two Different Orders Of Commissioner Of Income Tax (Appeal), National Faceless Appeal Centre (Nfac), Delhi Both Dated 24.07.2025, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called 'The Act'). The Relevant Assessment Year Is 2015-16.

For Appellant: Shri Y. Sridhar, FCAFor Respondent: Ms. Gouthami Manivasagam, JCIT

Section 144BSection 147Section 148Section 148ASection 250

आयकर अपीलीय अधिकरण, 'बी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'B' BENCH, CHENNAI श्री जॉर्ज जॉर्ज के, उपाध्यक्ष