Faceless Assessment & Faceless Appeal Scheme in India: How Tax Proceedings Work Without Meeting an Officer
- shubhamtulsian05
- Jun 17
- 4 min read
Until 2019, an income tax scrutiny meant visiting the Assessing Officer's office, carrying physical files, and often building a personal rapport with the officer handling your case — a system that, while functional, was also vulnerable to inconsistency and, in some cases, corruption. The Faceless Assessment Scheme, launched in 2019 and made the default mechanism by 2020, eliminated this entirely. Today, the vast majority of income tax assessments and appeals in India are conducted without the taxpayer ever knowing which officer is handling their case, or meeting them in person.
What is the Faceless Assessment Scheme?
Under the Faceless Assessment Scheme, scrutiny assessments are allocated randomly through an automated system to an Assessing Officer anywhere in the country — not necessarily in the taxpayer's home jurisdiction. The entire process — notices, document submission, queries, and the final order — happens through the income tax e-filing portal.
The Institutional Structure Behind Faceless Assessment
National Faceless Assessment Centre (NaFAC): The central hub that coordinates the entire faceless assessment process, allocating cases to various assessment units.
Assessment Units: Teams of officers spread across the country who actually examine the case, request information, and propose additions if warranted — but who never directly communicate with the taxpayer.
Verification Units: Separate teams that conduct any factual verification required (cross-checking information with third parties, banks, or other agencies) without revealing this process to the taxpayer directly.
Technical Units: Provide specialised technical input on complex legal or valuation questions arising in the assessment.
Review Units: Review the draft assessment order prepared by the Assessment Unit before it is finalised — adding a layer of internal quality control absent in the earlier system.
How a Faceless Assessment Proceeds — Step by Step
Step 1 — Notice issuance: Section 143(2) or 142(1) notices are issued through the e-filing portal, with no indication of which city or officer is handling the matter.
Step 2 — Document submission: The taxpayer (or their authorised representative) uploads all responses and supporting documents through the e-proceedings tab on the portal within the specified time.
Step 3 — Show Cause Notice (if additions proposed): If the Assessment Unit proposes any addition or disallowance, a Show Cause Notice with the draft variation is issued, giving the taxpayer an opportunity to respond before the order is finalised.
Step 4 — Personal hearing via video conference: Taxpayers have a statutory right to request a personal hearing through video conferencing if they believe written submissions are insufficient to explain their case — this is one of the most important rights under the faceless scheme and should be exercised whenever the case involves complex facts.
Step 5 — Final assessment order: The order is passed and communicated through the portal, along with any demand notice if additions are confirmed.
The Faceless Appeal Scheme — CIT(A) Proceedings
Similarly, the Faceless Appeal Scheme, 2021 governs appeals before the Commissioner of Income Tax (Appeals) — CIT(A). The structure mirrors faceless assessment: National Faceless Appeal Centre (NFAC) coordinates the process, with appeals allocated to Appeal Units across the country.
Filing the appeal: Form 35 is filed electronically along with grounds of appeal and a statement of facts.
Written submissions only, mostly: Unlike assessment, the faceless appeal process has historically been criticised for limited personal hearing opportunities — though taxpayers can specifically request a hearing, and CBDT guidelines direct that such requests should ordinarily be allowed, especially in cases involving substantial additions or complex issues.
Final order: The CIT(A) order is passed and uploaded to the portal, opening the door to further appeal before ITAT if adverse.
Practical Tips for Success Under the Faceless System
Front-load your documentation: Since there's no opportunity to build rapport or explain context informally, your written submission must be complete, well-organised, and self-contained from the first response.
Always request a video conference for complex matters: Don't rely solely on written submissions for cases involving disputed facts, valuation questions, or matters requiring detailed explanation — request the personal hearing explicitly.
Respond within time, every time: The faceless system is unforgiving of missed deadlines — there's no officer to call for an informal extension. Always submit a formal request for extension before the deadline if more time is needed.
Maintain a complete digital trail: Screenshot or save PDF copies of every notice, submission, and acknowledgment — the portal interface can sometimes be difficult to navigate retrospectively.
Engage a professional who understands portal mechanics: Beyond the legal and factual arguments, navigating the e-proceedings portal itself (upload limits, document formats, response windows) has become a specialised skill that affects case outcomes.
Criticisms and Ongoing Refinements
The faceless system has faced criticism for reduced opportunity for nuanced explanation, technical glitches on the portal causing missed deadlines through no fault of the taxpayer, and inconsistent application of personal hearing rights across different Assessment/Appeal Units. The CBDT has issued multiple clarificatory instructions over the years directing officers to be liberal in granting hearing requests and condoning genuine technical difficulties — taxpayers facing rejection of legitimate requests can cite these instructions.
How PGT & Associates Can Help
PGT & Associates has extensive experience navigating faceless assessment and appeal proceedings — preparing comprehensive written submissions designed for the faceless format, securing video conference hearings where needed, and managing the procedural aspects of the e-proceedings portal to ensure nothing is missed. Contact us at +91-87994-99189 for assistance with any pending faceless assessment or appeal.
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