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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

Venugopal Ravichandran, Chennai vs. ITO, Non Corp Ward 19(6)M Chennai, Chennai

In the result, the appeal of the assessee is allowed

ITA 2121/CHNY/2025[2016-17]Status: DisposedITAT Chennai25 Sept 2025AY 2016-17

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.2121/Chny/2025 Assessment Years: 2016-17 Venugopal Ravichandran Income Tax Officer, Old No.5, New No.7, Bhavani Street, Non Corp Ward-19(6), Bharathi Nagar, Tharamani, Ttti, Chennai. Taramani S.O, Taramani, Chennai-600 113. [Pan: Adypr7701G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr.T.S.Lakshmi Venkataraman,Fca प्रत्यर्थी की ओर से /Revenue By : Mr.Saujanya Ranjan, Irs सुनवाई की तारीख/Date Of Hearing : 24.09.2025 घोषणा की तारीख /Date Of Pronouncement : 25.09.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Mr.T.S.Lakshmi Venkataraman,FCAFor Respondent: Mr.Saujanya Ranjan, IRS
Section 147Section 148Section 151ASection 37

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 Bombay High Court held the view that allowing concurrent jurisdiction would lead

Oruvandur Pacb Ltd, Namakkal vs. ITO, Ward 2, Namakkal

In the result, the appeal of the assessee is allowed

ITA 2117/CHNY/2025[2019-20]Status: DisposedITAT Chennai25 Sept 2025AY 2019-20

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.2117/Chny/2025 Assessment Years: 2019-20 Oruvandur Pacb Ltd, Income Tax Officer, Orunvandur Po, Ward-2, Namakkal, Namakkal Tamil Nadu-637015, [Pan: Aaaao0407C] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr.T.S.Lakshmi Venkataraman, C.A प्रत्यर्थी की ओर से /Revenue By : Mr.Saujanya Ranjan, Irs सुनवाई की तारीख/Date Of Hearing : 24.09.2025 घोषणा की तारीख /Date Of Pronouncement : 25.09.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Mr.T.S.Lakshmi Venkataraman, C.AFor Respondent: Mr.Saujanya Ranjan, IRS
Section 147Section 148Section 148ASection 151Section 151ASection 80P

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 Bombay High Court held the view that allowing concurrent jurisdiction would lead

Manimala, Puducherry vs. ITO, Ward-3, Puducherry

In the result, the appeal of the assessee is allowed

ITA 2102/CHNY/2025[2019-20]Status: DisposedITAT Chennai25 Sept 2025AY 2019-20

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.2102/Chny/2025 Assessment Years: 2019-20 Manimala Income Tax Officer, 50A Saint Simone Pet, Ward-3, Muthialpet, Pondicherry Pondicherry-605 003. [Pan: Baspm8411L] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr.Suraj Nahar, C.A प्रत्यर्थी की ओर से /Revenue By : Mr.Saujanya Ranjan, Irs सुनवाई की तारीख/Date Of Hearing : 23.09.2025 घोषणा की तारीख /Date Of Pronouncement : 25.09.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Mr.Suraj Nahar, C.AFor Respondent: Mr.Saujanya Ranjan, IRS
Section 147Section 148Section 148ASection 151Section 151ASection 45

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 ... Bombay High Court held the view that allowing concurrent jurisdiction would lead to chaos and undermine the purpose of the faceless assessment scheme. It clarified that the scheme's automated allocation process randomly assigns cases to assessing officers, and in this case, the JAO was not the designated officer. Therefore

Diosma Lifesciences Private Limited, Mumbai vs. Income Tax Officer Ward 4(1) Thane, Thane

In the result, the appeal of the assessee is dismissed

ITA 4271/MUM/2025[2018-19]Status: DisposedITAT Mumbai16 Sept 2025AY 2018-19

Bench: Ms. Kavitha Rajagopal & Shri Prabhash Shankardiosma Lifesciences Private V/S. Income Tax Officer, Ward – Limited बनाम 4(1), Qureshi Mansion, Shop No. 77, C-Wing, Gokhale Road, Naupada, Harmony Mall Commercial Thane West, Thane - 400 Premises, Bhagat Singh Nagar 602, Maharashtra No.1, Link Road, Goregaon(West), Mumbai - 400 104, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aafcd0525R Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Vipul Shah, ARFor Respondent: Shri Aadesh Rai, Addl. CIT, (Virtually appeared)
Section 133(6)Section 143(2)Section 143(3)Section 37(1)

Appellant without appreciating the fact that the assessment was completed during the peak of the COVID-19 pandemic under the newly introduced faceless assessment scheme, and the alleged non- compliance stemmed from a lack of proper communication due to non- receipt of notices. 3. On the facts and circumstances ... assessee without appreciating the fact that the assessment was completed during the peak of the COVID-19 pandemic under the newly introduced Faceless assessment scheme and the alleged non-compliance stemmed from a lack of proper communication due to non-receipt of notices. 3.1 We have gone through the records

Kesar Buildcon Private Limited, Banaskantha vs. The PCIT, Ahmedabad-3, Ahmedabad

Accordingly, we set aside the order passed by the PCIT and restore the assessment order passed by the Assessing Officer. The appeal of the assessee is thus allowed

ITA 790/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad08 Sept 2025AY 2021-22

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2021-2028 Kesar Buildcon Pvt. Ltd. The Ld.Pr.Cit 1St Floor Shri Kesar Cold Vs. Ahmedabad-3 Storage Plot No.B-2 To 9, Rev Survey No.85/2 Paiki Near Hotel Jyoti Vil Banaskantha. Pan : Aabck 4923 E (Applicant) (Responent) : Shri Hem Chhajed, Ar Assessee By : Shri Rignesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 03/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 08/09/2025

For Appellant: Shri Rignesh Das, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 2(22)(e)Section 263Section 269S

copy of Instruction No. 1 dated 13.10.2021 issued by the CBDT, which lays down the modalities for conducting assessments under the Faceless Assessment Scheme and delineates the scope of limited scrutiny, complete scrutiny and compulsory scrutiny cases. Point No. 10, as reproduced from the Instruction, reads as under: “Notice ... also examined the “Proceedings Feedback” from the ITBA system placed on record. This feedback mechanism is an integral part of the Faceless Assessment Scheme and requires the Assessing Officer to mandatorily record (as per the said Instruction No.1) the outcome of verification on the identified CASS issues. The format

Mrs. Roopa Rathi, Chennai vs. ITO, Ncw-10(3), Chennai

In the result, the appeal of the assessee is allowed

ITA 1707/CHNY/2025[2018-19]Status: DisposedITAT Chennai04 Sept 2025AY 2018-19

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1707/Chny/2025 Assessment Years: 2018-19 Mrs.Roopa Rathi, Income Tax Officer, Door No.1, Damodar Murthy Street, Non-Corporate Ward-10(3), Kilpauk, Chennai. Chennai-600 010. [Pan: Ajapr6077R] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr.Hitesh, Advocate For Mr.D.Anand, Advocate. प्रत्यर्थी की ओर से /Revenue By : Ms.Gouthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 25.08.2025 घोषणा की तारीख /Date Of Pronouncement : 04.09.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Mr.Hitesh, Advocate for Mr.D.AnandFor Respondent: Ms.Gouthami Manivasagam, JCIT
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

Microsoft Corporation (India) Pvt Ltd, Delhi vs. DCIT (16) (1) Delhi, Delhi

Appeal of the assessee is allowed

ITA 1862/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Sept 2025AY 2017-18

Bench: Shri Mahavir Singh, Vice Presdient (), Shri Vikas Awasthy & Shri Brajesh Kumar Singhआअसं.1862/िद"ी/2022 (िन.व. 2017-18) Microsoft Corporation (India) P. Ltd., 807, New Delhi House, Barakhamba Road, New Delhi 110001 ...... अपीलाथ"/Appellant Pan: Aaacm-5586-C बनाम Vs. Deputy Commissioner Of Income-Tax, Circle 16(1), Central Revenue Building, ..... "ितवादी/Respondent Ip Estate, Delhi अपीलाथ" "ारा/ Appellant By : S/Shri Nageswar Rao, (Through Vc) & Parth, Advocates "ितवादी"ारा/Respondent By : Shri Rajesh Kumar, Cit- Dr सुनवाई क" ितिथ/ Date Of Hearing : 04/09/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 04/09/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 30.06.2022, Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961, (Hereinafter Referred To As ‘The Act’) For Assessment Year 2017-18. 2. Shri Nageswar Rao, Appearing On Behalf Of The Assessee Submitted At The Outset That, At This Stage He Is Confining His Submissions To Ground No. 1 Of Appeal

For Appellant: S/Shri Nageswar Rao, (Through VC) &For Respondent: Shri Rajesh Kumar, CIT- DR
Section 143(3)Section 144C(13)Section 144C(5)

NFAC vs Automotive Manufacturers Private Limited in Civil Appeal No.1829 of 2023, in its order dated 21.03.2023, appreciated 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.In this case ... High Court has committed any error. The Hon’ble Court further held that 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