Faceless assessment framework breach under Section 151A invalidates jurisdictional assessment and appellate orders.

Assessments made by the jurisdictional Assessing Officer in breach of the statutory faceless assessment framework under Section 151A and the notified scheme are liable to be invalidated. Applying the earlier binding Division Bench view, the Andhra Pradesh HC held that notices and proceedings in similar circumstances were contrary to Section 151A, so the impugned assessment order and appellate order could not be sustained. The assessee's challenge succeeded, and both orders were set aside.

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Issues: Whether the assessment order and the appellate order were liable to be set aside on the ground that the proceedings were undertaken by the jurisdictional Assessing Officer contrary to Section 151A of the Income-tax Act, 1961 and the notified scheme.

Analysis: The dispute turned on whether the assessment process adopted in the case was permissible after the statutory scheme under Section 151A and the notification dated 29.03.2022. The Court applied the earlier Division Bench decision which had already considered the same legal question and held that notices issued in similar circumstances were contrary to Section 151A. Following that binding view, the impugned assessment and the appellate order could not be sustained.

Conclusion: The challenge succeeded. The assessment order and the appellate order were set aside in favour of the assessee.

Final Conclusion: The decision reiterates that proceedings carried out in breach of the statutory faceless assessment framework and the mandate of Section 151A cannot stand.

Ratio Decidendi: Where the statutory assessment scheme under Section 151A is and binding, an assessment made by the jurisdictional Assessing Officer in contravention of that scheme is liable to be invalidated.

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