Faceless reassessment and delay condonation: reassessment upheld, while property and cash deposit additions were remanded for fresh scrutiny.

Delay in filing the Tribunal appeal was treated as supported by sufficient cause and condoned because the assessee acted promptly after noticing the appellate order. On the reassessment challenge, the faceless order was held not void or without jurisdiction merely because it was processed through NFAC; the statutory scheme under the reassessment and faceless assessment framework was read as not invalidating the order on that ground. The additions relating to purchase of property and cash deposits were not decided on merits and were remanded to the Assessing Officer for fresh examination after giving the assessee an opportunity to explain the s.

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Issues: (i) Whether the delay in filing the appeal before the Tribunal deserved to be condoned; (ii) whether the reassessment order passed through the faceless mechanism on 26.03.2022 was without jurisdiction and non est; (iii) whether the additions towards purchase of property and cash deposits required adjudication on merits or remand.

Issue (i): Whether the delay in filing the appeal before the Tribunal deserved to be condoned.

Analysis: The assessee explained the delay by stating that the appellate order was actually noticed later through the email demand communication and that the appeal was filed promptly after obtaining the order and consulting counsel. The Tribunal accepted the explanation as sufficient cause and treated the delay as bona fide.

Conclusion: The delay was condoned in favour of the assessee.

Issue (ii): Whether the reassessment order passed through the faceless mechanism on 26.03.2022 was without jurisdiction and non est.

Analysis: The Tribunal examined the scheme under Section 151A and the faceless reassessment framework under Section 144B, including the effect of the later substitution from 01.04.2022. It held that the reassessment notice was issued before the commencement of the e-Assessment of Income Escaping Assessment Scheme, 2022, and that the statutory regime did not render the impugned reassessment void merely because it was processed through NFAC. The relied-upon coordinate bench decisions were held not to govern the case in view of the subsequent statutory analysis.

Conclusion: The jurisdictional challenge failed and the reassessment order was held valid.

Issue (iii): Whether the additions towards purchase of property and cash deposits required adjudication on merits or remand.

Analysis: The Tribunal noted that the lower authorities had not decided the merits after the assessee's non-participation. Since the assessee sought an opportunity to substantiate the source of the property transaction and cash deposits, the Tribunal restored the matter to the Assessing Officer for fresh examination in accordance with law.

Conclusion: The merits were remanded to the Assessing Officer for fresh adjudication.

Final Conclusion: The appeal succeeded only to the extent of restoration on the merits, while the jurisdictional challenge to the reassessment failed.

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