Faceless assessment jurisdiction fails where the assessment is completed before the scheme becomes effective.

An assessment framed by the National Faceless Assessment Centre before the faceless assessment notification became effective was without jurisdiction under sections 147, 144B and 151A of the Income-tax Act, 1961, because the faceless assessment mechanism had not yet commenced on the date of the order. The jurisdictional defect rendered the assessment unsustainable, and the impugned order was quashed. The appeal thus succeeded on the threshold issue of competence to make the assessment.

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Issues: Whether the assessment order framed by the National Faceless Assessment Centre before the faceless assessment notification became effective was without jurisdiction and liable to be quashed.

Analysis: The assessment was completed under sections 147 and 144B of the Income-tax Act, 1961, in the context of section 151A and the notification making the faceless assessment mechanism effective from 29.03.2022. Since the assessment order in question was passed before that effective date, the jurisdiction of the National Faceless Assessment Centre to frame the assessment was not available on the date of the order.

Conclusion: The assessment order was held to be without jurisdiction and was quashed.

Final Conclusion: The appeal succeeded on the jurisdictional objection and the impugned assessment was set aside.

Ratio Decidendi: An assessment framed by the National Faceless Assessment Centre before the faceless assessment scheme becomes effective is without jurisdiction and cannot be sustained.

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