Faceless Assessment Mechanism: Jurisdictional Limits in Income Tax Proceedings

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....ses the intricate interplay between statutory provisions and administrative mechanisms in the realm of income tax proceedings. The court's decision sheds light on the jurisdictional limitations imposed by the faceless assessment scheme, a pioneering initiative aimed at enhancing transparency and efficiency in tax assessments. Arguments Presented The primary contention raised by the revenue a....

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....dated March 31, 2021, and September 6, 2021, issued u/s 119 of the Act, apply exclusively to "assessment orders" to be passed and do not extend to proceedings u/ss 148A and 148 of the Act. * The scheme notified u/s 151A, through the notification dated March 29, 2022, is not subject to the applicability of the aforementioned orders, nor does it explicitly include their applicability. ....

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....rview of the faceless mechanism and were, therefore, illegal and without jurisdiction. * The court reiterated its earlier decisions in Hexaware Technologies Limited and CapitalG LP, which consistently held that proceedings u/ss 148A and 148 of the Act, even in cases involving central charges and international taxation charges, must be conducted in a faceless manner, as mandated by Sections 144B ....