Faceless assessment jurisdiction attaches only after notification; assessment framed before notification was invalid and was quashed.

Faceless assessment framed before the enabling notification lacks jurisdiction: the note analyses the temporal relationship between the statute enabling faceless assessments and the notification bringing the scheme into force, concluding that jurisdiction to conduct faceless assessments attaches only after the scheme is notified; an assessment dated 13.03.2022, predating Notification No.18/2022 (29.03.2022), was therefore without jurisdiction and quashed, with the appeal allowed for the assessee. The reasoning rests on notification operability and supporting precedents addressing similar timing and jurisdictional issues.

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Issues: Whether the assessment framed by the National Faceless Assessment Centre (NFAC) on 13.03.2022 is valid given that the faceless assessment scheme under Section 151A of the Income-tax Act, 1961 was notified only on 29.03.2022.

Analysis: The Court examined the temporal relationship between the statutory provision enabling faceless assessments and the notification bringing faceless assessment procedures into operation. Section 151A of the Income-tax Act, 1961 was enacted on the statute book earlier but the faceless assessment provisions were notified by Notification No. 18/2022 dated 29.03.2022. The assessment impugned was framed on 13.03.2022, prior to the notification date. The Court considered that faceless assessment jurisdiction attaches only after the scheme is brought into force by notification and noted supporting precedents of coordinate and higher courts addressing similar temporal and jurisdictional issues.

Conclusion: The assessment dated 13.03.2022 framed by the NFAC is without jurisdiction and is quashed. The appeal is allowed in favour of the assessee.

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