Faceless reassessment without jurisdiction when initiated before the operative scheme notification, making the proceedings void.

Faceless reassessment proceedings under the income-tax faceless assessment framework were held to be without jurisdiction where the applicable scheme for income escaping assessment had not yet become operative on the relevant dates. Section 151A was treated as governing such faceless reassessment, but the notified scheme came into force only on 29.03.2022, while the notice under section 143(2), the show-cause notice, and the assessment order had all been issued earlier. On that basis, proceedings conducted by the National Faceless Assessment Centre were incapable of being sustained and were quashed.

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Issues: Whether the reassessment framed through the faceless assessment mechanism was without jurisdiction because the faceless scheme for income escaping assessment had not become operative on the relevant dates.

Analysis: Section 151A of the Income-tax Act, 1961 was held to govern faceless assessment of income escaping assessment, but the applicable scheme was notified only on 29.03.2022. The notice under section 143(2), the show-cause notice, and the assessment order were all issued before that date. On that footing, the reassessment proceedings undertaken by the National Faceless Assessment Centre were treated as lacking jurisdiction and incapable of being sustained.

Conclusion: The reassessment was held to be without jurisdiction and was quashed in favour of the assessee.

Ratio Decidendi: Faceless reassessment proceedings initiated before the operative notification of the applicable scheme are void for want of jurisdiction.

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