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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

Govind Corporation, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

ITA 3230/MUM/2025[2015-16]Status: DisposedITAT Mumbai28 Oct 2025AY 2015-16
Section 132Section 132(4)Section 69A

reopened under section 147 are quashed as void ab initio for having been initiated by an officer lacking jurisdiction in contravention of the Faceless Assessment Scheme under section 151A (ii) the assessment orders themselves are invalidated for non-compliance with CBDT Circular No. 19 of 2019 due to the absence

Veda Real Estate Corporation Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

ITA 3220/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Oct 2025AY 2012-13
Section 131Section 132Section 132(4)Section 134Section 69A

Having held so, it necessarily follows that the reassessment proceedings initiated under section 148 by the jurisdictional Assessing Officer, in violation of the Faceless Assessment Scheme under section 151A and compounded by the failure to generate and quote a valid DIN, stand vitiated in law. The dual breaches one jurisdictional ... reassessment proceedings and the resultant assessment orders are unsustainable. The notice under section 148, issued by an authority bereft of jurisdiction under the Faceless Assessment Scheme, is void ab initio. The assessment order, bereft of a valid, pre-generated DIN, stands condemned by the express stipulations of CBDT Circular

Tarun Nandkumar Seksaria, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

ITA 3216/MUM/2025[2015-16]Status: DisposedITAT Mumbai28 Oct 2025AY 2015-16
Section 132Section 132(4)Section 69A

reassessment proceedings and the resultant assessment orders are unsustainable. The notice under Section 148, issued by an authority bereft of jurisdiction under the Faceless Assessment Scheme, is void ab initio. The Revenue, though afforded ample opportunity, has not demonstrated compliance with any of the statutory or procedural conditions that could ... deleted for want of evidence; (ii) the reassessment proceedings initiated under section 148 are quashed for lack of jurisdiction in terms of the Faceless Assessment Scheme. The remaining grounds pertaining to interest under Sections 234B are purely consequential and call for no separate adjudication. The appeals filed by the assessees

Tarun Nandkumar Seksaria, Mumbai vs. DCIT Central Circle 8(1), Mumbai

ITA 3215/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Oct 2025AY 2016-17
Section 132Section 132(4)Section 69A

reassessment proceedings and the resultant assessment orders are unsustainable. The notice under Section 148, issued by an authority bereft of jurisdiction under the Faceless Assessment Scheme, is void ab initio. The Revenue, though afforded ample opportunity, has not demonstrated compliance with any of the statutory or procedural conditions that could ... deleted for want of evidence; (ii) the reassessment proceedings initiated under section 148 are quashed for lack of jurisdiction in terms of the Faceless Assessment Scheme. The remaining grounds pertaining to interest under Sections 234B are purely consequential and call for no separate adjudication. The appeals filed by the assessees

Ei Resorts and Clubs Pvt Ltd, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

3213/Mum/2025

ITA 3213/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Oct 2025AY 2012-13
Section 132Section 132(4)Section 69A

reassessment proceedings and the resultant assessment orders are unsustainable. The notice under Section 148, issued by an authority bereft of jurisdiction under the Faceless Assessment Scheme, is void ab initio. The assessment order, bereft of a valid, pre-generated DIN, stands condemned by the express stipulations of CBDT Circular ... evidence; (ii) the reassessment proceedings initiated under Section 148 are quashed as void ab initio for lack of jurisdiction in terms of the Faceless Assessment Scheme; and (iii) the assessment orders are further invalidated for non-compliance with CBDT Circular No. 19 of 2019 owing to the absence

Flint Power Tools (P) Ltd, Gurugram vs. ACIT, Central Circle-1, Faridabad

In the result, the appeal of the assessee is allowed

ITA 5642/DEL/2024[2019-20]Status: DisposedITAT Delhi27 Oct 2025AY 2019-20

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2019-20 M/S. Flint Power Tools (P) Vs. Assistant Commissioner Of Ltd., Income Tax, Plot Nos. 594, 595, Central Circle-1, Sector 8 Imt Manesar, Faridabad-I, New-1 Gurugram, Haryana Pan: Aadcn0078K (Appellant) (Respondent)

For Appellant: Shri Lalit Mohan, CA & Shri AnkitFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 132Section 142(1)Section 147Section 148Section 151Section 151ASection 250(6)Section 37

residential as well as office premises of LSL Tools Group of companies and others. Consequent upon implementation of the Faceless Assessment Scheme, Search cases were transferred from the jurisdictional assessing authorities to the central charges by the Ld. PCIT, Gurugram vide order dated 23.12.2022. The case of the assessee

Meenakshi Academy of Higher Education & Research (Maher), Chennai vs. Income Tax Officer, Exemptions Ward 3, Chennai

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

ITA 2323/CHNY/2025[2018-19]Status: DisposedITAT Chennai24 Oct 2025AY 2018-19

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.2323/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 Meenakshi Academy Of Higher Vs. The Income Tax Officer, Education & Research [Maher], Exemptions Ward 3, 12, Vembuli Amman Koil Street, Chennai. West K.K. Nagar, Chennai 600 078. [Pan: Aaetm9880C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Venkata Raman, Ca ""थ" की ओर से/Respondent By : Shri C.P. Solomon, Jcit सुनवाई की तारीख/ Date Of Hearing : 23.10.2025 घोषणा की तारीख /Date Of Pronouncement : 24.10.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 08.08.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2018-19. 2. When The Appeal Was Taken Up For Hearing, The Ld. Ar Shri R. Venkata Raman, Ca Drew Our Attention To The Application Seeking Permission To File Additional Grounds Of Appeal Dated 23.10.2025 Placed

For Appellant: Shri R. Venkata Raman, CAFor Respondent: Shri C.P. Solomon, JCIT
Section 147Section 148Section 148ASection 151A

above grounds, that the notice issued u/s. 148 of the Act dated 30.03.2022, by the JAO, is in contravention of the Faceless Assessment Scheme notified by the Central Government on 29.03.2022 pursuant to section 151A of the Act, hence the same is invalid and bad in law. Consequently, the assessment

DCIT, Central Circle-8(1), Mumbai vs. The Estate Investment Company Pvt Ltd, Mumbai

3012/Mum/2025

ITA 3936/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Oct 2025AY 2017-18
Section 132Section 132(4)Section 69A

reassessment proceedings and the resultant assessment orders are unsustainable. The notice under section 148, issued by an authority bereft of jurisdiction under the Faceless Assessment Scheme, is void ab initio. The assessment order, bereft of a valid, pre-generated DIN, stands condemned by the express stipulations of CBDT Circular ... deleted for want of evidence; (ii) the reassessment proceedings initiated under section 148 are quashed for lack of jurisdiction in terms of the Faceless Assessment Scheme; and (iii) the assessment orders are further invalidated for non-compliance with CBDT Circular No. 19 of 2019 owing to the absence

DCIT, Central Circle-8(1), Mumbai vs. The Estate Investment Company Pvt Ltd, Mumbai

ITA 3928/MUM/2025[2015-16]Status: DisposedITAT Mumbai17 Oct 2025AY 2015-16
Section 132Section 132(4)Section 69A

reassessment proceedings and the resultant assessment orders are unsustainable. The notice under section 148, issued by an authority bereft of jurisdiction under the Faceless Assessment Scheme, is void ab initio. The assessment order, bereft of a valid, pre-generated DIN, stands condemned by the express stipulations of CBDT Circular ... deleted for want of evidence; (ii) the reassessment proceedings initiated under section 148 are quashed for lack of jurisdiction in terms of the Faceless Assessment Scheme; and (iii) the assessment orders are further invalidated for non-compliance with CBDT Circular No. 19 of 2019 owing to the absence

The Estate Investment Company Private Limited, Mumbai vs. DCIT Central Circle 8(1), Mumbai

ITA 3228/MUM/2025[2015-16]Status: DisposedITAT Mumbai17 Oct 2025AY 2015-16
Section 132Section 132(4)Section 69A

reassessment proceedings and the resultant assessment orders are unsustainable. The notice under section 148, issued by an authority bereft of jurisdiction under the Faceless Assessment Scheme, is void ab initio. The assessment order, bereft of a valid, pre-generated DIN, stands condemned by the express stipulations of CBDT Circular ... deleted for want of evidence; (ii) the reassessment proceedings initiated under section 148 are quashed for lack of jurisdiction in terms of the Faceless Assessment Scheme; and (iii) the assessment orders are further invalidated for non-compliance with CBDT Circular No. 19 of 2019 owing to the absence

The Estate Investment Company Private Limited, Mumbai vs. DCIT Central Circle 8(1), Mumbai

3012/Mum/2025

ITA 3227/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Oct 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 69A

reassessment proceedings and the resultant assessment orders are unsustainable. The notice under section 148, issued by an authority bereft of jurisdiction under the Faceless Assessment Scheme, is void ab initio. The assessment order, bereft of a valid, pre-generated DIN, stands condemned by the express stipulations of CBDT Circular ... deleted for want of evidence; (ii) the reassessment proceedings initiated under section 148 are quashed for lack of jurisdiction in terms of the Faceless Assessment Scheme; and (iii) the assessment orders are further invalidated for non-compliance with CBDT Circular No. 19 of 2019 owing to the absence

The Estate Investment Company Private Limited, Mumbai vs. DCIT Central Circle 8(1), Mumbai

ITA 3225/MUM/2025[2019-20]Status: DisposedITAT Mumbai17 Oct 2025AY 2019-20
Section 132Section 132(4)Section 69A

reassessment proceedings and the resultant assessment orders are unsustainable. The notice under section 148, issued by an authority bereft of jurisdiction under the Faceless Assessment Scheme, is void ab initio. The assessment order, bereft of a valid, pre-generated DIN, stands condemned by the express stipulations of CBDT Circular ... deleted for want of evidence; (ii) the reassessment proceedings initiated under section 148 are quashed for lack of jurisdiction in terms of the Faceless Assessment Scheme; and (iii) the assessment orders are further invalidated for non-compliance with CBDT Circular No. 19 of 2019 owing to the absence

The Estate Investment Company Private Limited, Mumbai vs. DCIT Central Circle 8(1), Mumbai

3012/Mum/2025

ITA 3224/MUM/2025[2020-21]Status: DisposedITAT Mumbai17 Oct 2025AY 2020-21
Section 132Section 132(4)Section 69A

reassessment proceedings and the resultant assessment orders are unsustainable. The notice under section 148, issued by an authority bereft of jurisdiction under the Faceless Assessment Scheme, is void ab initio. The assessment order, bereft of a valid, pre-generated DIN, stands condemned by the express stipulations of CBDT Circular ... deleted for want of evidence; (ii) the reassessment proceedings initiated under section 148 are quashed for lack of jurisdiction in terms of the Faceless Assessment Scheme; and (iii) the assessment orders are further invalidated for non-compliance with CBDT Circular No. 19 of 2019 owing to the absence

The Estate Investment Company Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

3012/Mum/2025

ITA 3223/MUM/2025[2021-22]Status: DisposedITAT Mumbai17 Oct 2025AY 2021-22
Section 132Section 132(4)Section 69A

reassessment proceedings and the resultant assessment orders are unsustainable. The notice under section 148, issued by an authority bereft of jurisdiction under the Faceless Assessment Scheme, is void ab initio. The assessment order, bereft of a valid, pre-generated DIN, stands condemned by the express stipulations of CBDT Circular ... deleted for want of evidence; (ii) the reassessment proceedings initiated under section 148 are quashed for lack of jurisdiction in terms of the Faceless Assessment Scheme; and (iii) the assessment orders are further invalidated for non-compliance with CBDT Circular No. 19 of 2019 owing to the absence

The Estate Investment Company Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

3012/Mum/2025

ITA 3222/MUM/2025[2022-23]Status: DisposedITAT Mumbai17 Oct 2025AY 2022-23
Section 132Section 132(4)Section 69A

reassessment proceedings and the resultant assessment orders are unsustainable. The notice under section 148, issued by an authority bereft of jurisdiction under the Faceless Assessment Scheme, is void ab initio. The assessment order, bereft of a valid, pre-generated DIN, stands condemned by the express stipulations of CBDT Circular ... deleted for want of evidence; (ii) the reassessment proceedings initiated under section 148 are quashed for lack of jurisdiction in terms of the Faceless Assessment Scheme; and (iii) the assessment orders are further invalidated for non-compliance with CBDT Circular No. 19 of 2019 owing to the absence

DCIT Central Circle-8(1), Mumbai vs. The Estate Investment Company Private Limited, Mumbai

3012/Mum/2025

ITA 3087/MUM/2025[2016-17]Status: DisposedITAT Mumbai17 Oct 2025AY 2016-17
Section 132Section 132(4)Section 69A

reassessment proceedings and the resultant assessment orders are unsustainable. The notice under section 148, issued by an authority bereft of jurisdiction under the Faceless Assessment Scheme, is void ab initio. The assessment order, bereft of a valid, pre-generated DIN, stands condemned by the express stipulations of CBDT Circular ... deleted for want of evidence; (ii) the reassessment proceedings initiated under section 148 are quashed for lack of jurisdiction in terms of the Faceless Assessment Scheme; and (iii) the assessment orders are further invalidated for non-compliance with CBDT Circular No. 19 of 2019 owing to the absence

The Estate Investment Company Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

ITA 3012/MUM/2025[2014-15]Status: DisposedITAT Mumbai17 Oct 2025AY 2014-15
Section 132Section 132(4)Section 69A

reassessment proceedings and the resultant assessment orders are unsustainable. The notice under section 148, issued by an authority bereft of jurisdiction under the Faceless Assessment Scheme, is void ab initio. The assessment order, bereft of a valid, pre-generated DIN, stands condemned by the express stipulations of CBDT Circular ... deleted for want of evidence; (ii) the reassessment proceedings initiated under section 148 are quashed for lack of jurisdiction in terms of the Faceless Assessment Scheme; and (iii) the assessment orders are further invalidated for non-compliance with CBDT Circular No. 19 of 2019 owing to the absence

DCIT- 27(2), Mumbai, Vashi, Navi Mumbai vs. Nayan Builders, Ghatkopar East, Mumbai

In the result, the appeal filed by the revenue is dismissed in above

ITA 4039/MUM/2023[201819]Status: DisposedITAT Mumbai14 Oct 2025

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhan

Section 115BSection 250Section 68

shown income from business or profession and income from other sources. The case was selected for limited scrutiny through CASS under faceless assessment scheme (FAS) to verify i) Income from Real Estate Business, ii) Unsecured Loans and iii) Business Expenses. Regarding the unsecured loan, assessee was asked to explain

Bhawani Developers, Lucknow vs. Income Tax Officer-4(1), Lucknow-New

Appeal is disposed of in accordance with the aforesaid

ITA 253/LKW/2025[2018-19]Status: DisposedITAT Lucknow09 Oct 2025AY 2018-19

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 115BSection 133(6)Section 142(1)Section 144BSection 147Section 68

provides that section 127 off the Act will apply, subject to exceptions, modifications and adaptations as stipulated therein, i.e. the faceless assessment scheme has not modified section 127 of the Act. The notification No. 64/2020 dated 13 August 2020 issued by the CBDT uses the term concurrently', which demonstrates that

Income-Tax Officer, Ward-1, Raichur vs. Maralbid Padmavathi, Raichur

In the result, appeal filed by theRevenue is dismissed

ITA 1006/BANG/2025[2016-17]Status: DisposedITAT Bangalore07 Oct 2025AY 2016-17

Bench: Shri.Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year : 2016-17 Ito, Vs. Maralbid Padmavathi, Ward – 1, 4-4-145, Zahirabad Raichur, Raichur. Raichur – 584 101, Karnataka. Pan :Anhpp 8615 N Appellant Respondent Assessee By : Shri. Narendra Sharma, Advocate Revenue By : Shri. Shankar Ganesh D, Addl. Cit(Dr)(Itat), Bangalore. Date Of Hearing : 12.08.2025 Date Of Pronouncement : 07.10.2025

For Appellant: Shri. Narendra Sharma, AdvocateFor Respondent: Shri. Shankar Ganesh D, Addl. CIT(DR)(ITAT), Bangalore
Section 139Section 142(1)Section 143(2)Section 147Section 148Section 271(1)(b)

Therefore Notice u/s 143(2) of the Act was issued on 14/09/2021. Thenafter, the case has been received under faceless assessment scheme on 11/11/2021. Therefore detailed questionnaire was issued to the assessee U/s. 142(1) of the Act vide dated 07/12/2021. The assessee has not furnished his reply