Faceless Assessment jurisdiction invalid where assessment preceded administrative notification enabling faceless procedures, resulting in quashing.

Challenge concerns validity of a faceless assessment completed before issuance of the administrative notification operationalising the faceless-assessment provision; legal analysis contrasts statutory insertion of faceless assessment with the later administrative notification and treats jurisdiction as dependent on the notification's issuance, relying on coordinate and High Court precedents addressing identical timing issues; factual posture involves reopening under the reassessment provisions after a return filed under the ordinary filing provision; conclusion stated in the text is that the faceless assessment completed prior to the notification was without jurisdiction and was quashed.

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Issues: Whether the assessment framed by the National Faceless Assessment Centre dated 22.03.2022 is without jurisdiction and therefore void for want of a valid notification empowering faceless assessment under Section 151A of the Income-tax Act, 1961.

Analysis: The assessee's return was filed under Section 139(1) of the Income-tax Act, 1961 and the assessment proceedings were initiated by reopening under Section 147 by issuance of notice under Section 148 followed by proceedings under Section 142(1). Section 151A of the Income-tax Act, 1961 provides for faceless assessment; the relevant notification enabling faceless assessment (Notification No. 18/2022/F. No. 370142/16/2022-TPL(Part)) was issued on 29.03.2022. The assessment impugned was completed on 22.03.2022, prior to the date of the notification; the Taxation and Other Law (realization and amendment of certain provisions) Act, 2020 brought faceless assessment provisions onto the statute book with effect from 01.11.2020 but administrative notification to operationalize Section 151A was issued only on 29.03.2022. Co-ordinate and High Court decisions on identical questions were relied upon in which assessments completed before the notification were held to be without jurisdiction.

Conclusion: The assessment framed by the National Faceless Assessment Centre dated 22.03.2022 is quashed as being without jurisdiction. The appeal is allowed in favour of the assessee.

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