Procedural fairness: faceless assessment set aside where prior judicial directions failed to reach AO; documents supplied and fresh adjudication ordered.

Challenge to a faceless assessment under Section 144C(1) turned on procedural fairness where an earlier judicial direction supplying relied-upon agreements did not reach the assessing authority due to a communication lapse; the court set aside the impugned assessment for want of receipt of those directions and of opportunity to reply, directed supply of the relied documents with permissible redactions, allowed a limited period to file a reply, required the Transfer Pricing Officer/AO to pass a fresh order within extended timelines, and extended statutory timelines to secure effective adjudication in accordance with fair hearing principles.

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Issues: Whether the order dated 10.02.2026 passed under Section 144C(1) of the Income-tax Act, 1961 by the Faceless Assessing Officer can be sustained where an earlier High Court order dated 06.02.2026 in the same matter did not reach the Assessing Officer due to a communication gap.

Analysis: The dispute concerns the validity of an assessment order passed after a prior High Court order in the same matter had been pronounced but, owing to a communication lapse, had not been received by the Faceless Assessing Officer. The legal framework includes procedural fairness and the statutory scheme for faceless assessments under Section 144C(1) of the Income-tax Act, 1961, as well as the procedural safeguards in transfer pricing proceedings requiring provision of relied upon documents and opportunity to reply. In the circumstances where the earlier judicial order directed supply of relied upon agreements, and those directions had not been placed before the Assessing Officer due to a communication failure, the assessment order was rendered without the assessment authority having the benefit of the earlier judicial direction and without the parties having the intended procedural opportunities. The remedy applied entails setting aside the impugned assessment order, directing compliance with the earlier judicial directions (supply of agreements with permissible redaction), permitting filing of a reply within a specified timeframe, and mandating the TPO/AO to pass fresh orders within extended timelines to secure effective adjudication of disputes in accordance with principles of fairness.

Conclusion: The impugned order dated 10.02.2026 is set aside; the petitioner is directed to be supplied the relied upon agreements with permissible redaction, shall file a reply by 16.03.2026, and the Transfer Pricing Officer shall pass a fresh order by 16.04.2026; all timelines before the TPO/AO and DRP are extended by sixty days and the writ petition is allowed.

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