Faceless AssessmentSection 144BIncome TaxE-ProceedingsDIN Validation

Faceless Assessment (Section 144B): Complete Guide for CAs in 2026

Learn how to handle Faceless Assessment notices under Section 144B — DIN validation, e-proceedings portal submissions, and multi-round query tracking for Indian CAs.

TaxNoticeAI Team16 min read

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Faceless Assessment under Section 144B has fundamentally changed how CAs interact with the Income Tax Department. Gone are the days of face-to-face meetings with the Assessing Officer at the local ward office. Since its rollout in 2020, every scrutiny assessment now flows through an anonymous, technology-driven process managed by the National Faceless Assessment Centre (NaFAC).

For Chartered Accountants handling multiple clients, this shift brings both opportunities and challenges. The good news: no more travel to ITO offices, no more adjournments based on officer availability, and a more standardized process. The challenge: strict digital deadlines, specific upload formats, and multi-round proceedings that require meticulous tracking. This guide covers everything you need to know about handling Section 144B assessments effectively in 2026.

What is Faceless Assessment (Section 144B)?

Background and Legislative History

Section 144B was introduced by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, replacing the earlier Faceless Assessment Scheme 2019 that was launched as an executive order. The provision was further amended by the Finance Act 2021 to address procedural gaps identified during the initial rollout.

The legislative intent behind Section 144B is straightforward: eliminate the human interface between the assessee and the Assessing Officer to reduce corruption, improve efficiency, and ensure uniformity in assessment proceedings across the country.

CBDT Notification and Objectives

CBDT Notification No. 60/2020 dated August 13, 2020, formally launched the Faceless Assessment Scheme. The stated objectives were:

  1. Elimination of human interface — No physical meeting between the assessee and the AO
  2. Team-based assessment — Assessment by a team of officers instead of a single AO
  3. Dynamic jurisdiction — Cases allocated randomly through automated systems
  4. Standardization — Uniform approach to similar issues across the country
  5. Accountability — Complete audit trail of every action in the proceedings

The scheme applies to all assessment orders passed under Sections 143(3), 144, and 147 (read with Section 143(3)), subject to certain exceptions notified by CBDT from time to time.

How the Faceless Assessment Machinery Works

Understanding the organizational structure behind faceless assessments is critical for CAs. It is not a single officer reviewing your client's case — it is a multi-layered system with distinct functional units.

National Faceless Assessment Centre (NaFAC)

NaFAC is the central coordinating body based in Delhi. It serves as the single point of communication between the assessee and the department. All notices, queries, and orders flow through NaFAC. The assessee never knows which officer or unit is handling the case, and the officer never knows the identity or location of the assessee (in theory).

NaFAC's responsibilities include:

  • Receiving and allocating cases to Assessment Units
  • Forwarding responses from assessees to the relevant units
  • Coordinating between Assessment Units, Verification Units, Technical Units, and Review Units
  • Issuing final assessment orders

Assessment Units (AUs)

Assessment Units are the primary functional units that conduct the assessment. They are spread across the country and cases are assigned to them randomly by NaFAC's automated allocation system. An AU performs the following functions:

  • Identifying issues for examination
  • Seeking information or clarification from the assessee
  • Analyzing submissions and evidence
  • Preparing a draft assessment order

An AU may request assistance from Verification Units or Technical Units during the process.

Verification Units (VUs)

When the Assessment Unit needs factual verification — such as confirming the existence of an asset, verifying a transaction with a bank, or conducting an inquiry with a third party — it requests NaFAC to assign the task to a Verification Unit. The VU conducts the verification and reports its findings back through NaFAC.

Technical Units (TUs)

For complex legal or technical issues, the Assessment Unit can request assistance from a Technical Unit. TUs provide opinions on points of law, applicability of judicial precedents, and interpretation of statutory provisions. This is particularly relevant in cases involving transfer pricing, international taxation, or novel legal questions.

Review Units (RUs)

Before a draft assessment order is finalized, it may be sent to a Review Unit for quality control. The RU examines whether the draft order is consistent with facts, law, and judicial precedents. If the RU finds deficiencies, it sends the draft back to the AU with suggestions for modification.

This multi-layered structure means that your client's response is potentially reviewed by multiple teams of officers. Your submissions need to be self-contained, clearly structured, and legally sound — you cannot rely on verbal explanations or informal discussions to fill gaps.

DIN Validation: Why It Matters

What is DIN?

Document Identification Number (DIN) is a unique computer-generated identification number that must be present on every communication issued by the Income Tax Department. This requirement was introduced by CBDT Circular No. 19/2019 dated August 14, 2019.

CBDT Circular 19/2019

The circular mandates that every communication from the department — including notices, orders, summons, letters, and any other correspondence — must carry a valid DIN. Communications without a DIN are treated as invalid and non-est in law (as if they were never issued).

The only exceptions are:

  1. Communications in search and seizure proceedings under Section 132
  2. Communications arising from survey operations under Section 133A
  3. Arrest and prosecution situations under Section 132A
  4. Situations where technical difficulties are recorded in writing by the officer

Why CAs Must Validate DIN

DIN validation is your first line of defense when a client receives a faceless assessment notice. Here is why:

  1. Jurisdictional challenge — A notice without a valid DIN is void ab initio. Multiple High Courts have quashed assessment orders where notices lacked valid DINs. The Allahabad High Court in Brandix Mauritius Holdings Ltd. v. ACIT (2022) held that the absence of DIN renders the communication invalid.

  2. Fraud detection — Fraudulent notices purporting to be from the Income Tax Department are increasingly common. DIN validation confirms the notice genuinely originated from the department's systems.

  3. Audit trail — A valid DIN confirms the notice was generated through proper channels and has been recorded in the department's central system.

How to Validate DIN

You can validate a DIN on the Income Tax Department's e-filing portal:

  1. Visit the e-filing portal (incometax.gov.in)
  2. Navigate to "Authenticate Notice/Order" under the "Quick Links" section
  3. Enter the DIN/Notice number, PAN, and Assessment Year
  4. The system confirms whether the notice is genuine and provides details

If the DIN does not validate, document this immediately and consider filing a written objection challenging the validity of the notice.

E-Proceedings Portal: How to Respond

Accessing the Portal

All responses to faceless assessment proceedings must be submitted through the e-Proceedings facility on the Income Tax e-filing portal. Physical submissions are not accepted.

To access e-Proceedings:

  1. Log in to incometax.gov.in with your client's credentials
  2. Navigate to "Pending Actions" then "E-Proceedings"
  3. You will see a list of all pending proceedings for the PAN
  4. Click on the relevant proceeding to view the notice and submit a response

Response Submission Process

When submitting a response through e-Proceedings:

  1. Read the notice carefully — Identify every specific query raised. Faceless assessment notices often contain multiple numbered queries that each require a specific response.

  2. Prepare your response document — Structure it as a formal submission with:

    • Reference to the notice number, DIN, and date
    • The specific query being addressed (quote the exact text)
    • Your detailed response with factual and legal reasoning
    • List of supporting documents attached
  3. Upload supporting documents — The portal accepts PDF files. There are file size limits (typically 10 MB per file, 50 MB total per submission). Organize documents logically with clear file names.

  4. Submit within the deadline — The notice specifies a deadline for response. Extensions can be requested through the portal but are not guaranteed.

Upload Formats and Size Limits

The e-Proceedings portal has specific technical requirements:

ParameterRequirement
File formatPDF only
Maximum file size10 MB per file
Total upload limit50 MB per submission
File namingAlphanumeric, no special characters
Document typesWritten submission, balance sheets, bank statements, agreements, invoices, etc.

Pro tip: If your supporting documents exceed the size limit, compress PDFs using tools like Adobe Acrobat or Smallpdf. For large volumes of documents, create a well-indexed compilation with a table of contents as the first page.

Deadlines and Extensions

Standard response deadlines in faceless assessments:

  • Initial response to notice: Usually 7-15 days from the date of the notice
  • Subsequent rounds: Usually 7 days from the date of the follow-up query
  • Adjournment/extension requests: Submit through e-Proceedings with specific reasons

If you need more time, file an adjournment petition through the portal immediately. Do not wait until the deadline has passed. NaFAC grants extensions more readily when the request is made in advance with legitimate reasons (e.g., voluminous records, client is travelling, CA is handling hearing dates).

Multi-Round Queries: How Proceedings Work

The Typical Flow

Faceless assessments rarely conclude in a single round. Here is the typical multi-round flow:

Round 1: Initial Notice and Response

  • NaFAC issues the initial notice (Section 143(2) read with 144B) identifying issues for examination
  • You submit your response with supporting documents through e-Proceedings
  • The Assessment Unit reviews your submission

Round 2: Follow-up Queries

  • Based on your initial response, the AU raises further queries — these are typically more specific and targeted
  • You respond with additional details, documents, or clarifications
  • This is often where the AU zeroes in on specific transactions or claims

Round 3 and Beyond

  • Additional rounds may follow depending on the complexity of the case
  • Each round narrows the scope of inquiry
  • The AU may also share verification reports from VUs that you need to respond to

Draft Assessment Order

  • Once the AU is satisfied (or the time limit is approaching), it prepares a draft assessment order
  • The draft may be sent to a Review Unit for quality review
  • If additions are proposed, NaFAC issues a show cause notice under Section 144B(1)(xvi) before finalizing

Final Assessment Order

  • After considering your response to the show cause notice, NaFAC issues the final assessment order
  • The order is uploaded to e-Proceedings and sent to your registered email

Tracking Multiple Rounds

For CAs handling 20-50 faceless assessments simultaneously, tracking the status of each round across different clients is a significant operational challenge. You need to track:

  • Which notices have pending responses
  • Deadline for each pending response
  • Which round each proceeding is in
  • Documents already submitted vs. documents requested
  • Queries that overlap with previous rounds (to avoid contradictory submissions)

This is where systematic tracking becomes essential. A missed deadline in a faceless assessment can result in a best judgment assessment under Section 144 — where the AO completes the assessment based on available information without your client's input.

How TaxNoticeAI Handles Faceless Assessments

TaxNoticeAI has built-in support for Faceless Assessment proceedings under Section 144B. Here is how each feature maps to the challenges described above.

Automatic Detection

When you upload a notice PDF to TaxNoticeAI, the system automatically identifies it as a Faceless Assessment notice based on:

  • References to Section 144B in the notice text
  • NaFAC header and formatting patterns
  • DIN number patterns
  • E-proceedings reference numbers

You do not need to manually classify the notice. The AI recognizes the notice type and applies the appropriate analysis framework.

DIN Validation

TaxNoticeAI extracts the DIN from the uploaded notice and flags it for validation. The system checks the DIN format against CBDT's prescribed pattern and alerts you if:

  • The DIN is missing from the notice
  • The DIN format appears invalid
  • The notice may require manual DIN verification on the e-filing portal

This gives you an immediate first-pass check before diving into the substantive response.

Once the notice is classified, TaxNoticeAI's AI engine:

  1. Identifies every specific query raised in the notice
  2. Searches the legal corpus (3,100+ documents including case law, CBDT circulars, and tribunal orders) for relevant precedents
  3. Suggests a response strategy for each query
  4. Identifies procedural defenses available (time limitation, DIN issues, jurisdiction)
  5. Drafts a structured response with proper legal citations

Structured PDF Export for E-Proceedings

TaxNoticeAI generates a professionally formatted PDF response that is ready for upload to the e-Proceedings portal. The export includes:

  • Proper header with notice reference, DIN, and AY
  • Query-by-query structured response
  • Legal citations with case references
  • Table of contents for supporting documents
  • Formatting that meets e-Proceedings upload requirements

This saves significant time compared to manually formatting responses in Word or other tools.

Multi-Round Query Tracking

For each notice uploaded, TaxNoticeAI maintains a complete history of:

  • The original notice and your first response
  • Subsequent round queries and responses
  • Documents submitted in each round
  • Deadline tracking with alerts

When a follow-up query arrives, you upload it to the same case in TaxNoticeAI. The AI considers your previous submissions when drafting the follow-up response, ensuring consistency across rounds.

Step-by-Step Walkthrough for CAs

Here is a practical walkthrough of handling a Section 144B notice using TaxNoticeAI:

Step 1: Receive the Notice Your client forwards the faceless assessment notice received via email or the e-filing portal.

Step 2: Upload to TaxNoticeAI Log in to TaxNoticeAI, click "Upload Notice," and upload the PDF. Optionally attach the client's ITR and AIS/TIS for context (costs 3 credits instead of 1 but gives the AI much richer context for drafting the response).

Step 3: Review AI Analysis Within minutes, TaxNoticeAI presents:

  • Notice classification (Faceless Assessment — Section 144B)
  • DIN validation status
  • Key queries identified from the notice
  • Applicable legal provisions and case law
  • Suggested response strategy
  • Draft reply with citations

Step 4: Customize the Response Review the AI-generated draft. Add client-specific facts, modify arguments as needed, and attach supporting documents. The AI provides the legal framework; you bring the client-specific context.

Step 5: Export for E-Proceedings Download the formatted PDF response. Upload it to the e-Proceedings portal on incometax.gov.in along with supporting documents.

Step 6: Track Follow-ups When the next round of queries arrives, upload it to the same case in TaxNoticeAI. The system maintains continuity across rounds.

Frequently Asked Questions

Can the Assessing Officer still call for a personal hearing in faceless assessment?

Yes, but only in limited circumstances. Section 144B(7)(viii) provides that if a personal hearing is requested and the circumstances justify it, the hearing shall be conducted through video conferencing. Physical hearings are not permitted except in cases specifically excluded from the faceless scheme (such as search assessments, international tax cases, or cases assigned to Central Charges). In practice, CAs should submit a written request for video hearing through e-Proceedings if they believe the queries cannot be adequately addressed through written submissions alone.

What happens if I miss the deadline for responding to a faceless assessment notice?

If you do not respond within the specified deadline and do not obtain an extension, the Assessment Unit can proceed to make a best judgment assessment under Section 144. This is an ex-parte assessment where the AO determines the income based on whatever material is available — typically resulting in significant additions. Always file at least an adjournment request if you cannot meet the deadline. If you have already missed it, file your response immediately with an explanation for the delay. NaFAC has discretion to condone delays.

How do I challenge a faceless assessment order?

Faceless assessment orders can be challenged through the same appellate remedies as regular assessment orders: appeal to CIT(A) under Section 246A (now also faceless), or directly to ITAT if the issue involves a point of law already covered by a binding precedent. Additionally, if there are procedural irregularities (lack of DIN, violation of natural justice, non-consideration of submissions), you may consider a writ petition before the High Court under Article 226 of the Constitution.

Are transfer pricing cases covered under faceless assessment?

Currently, transfer pricing assessments are excluded from the faceless scheme. However, the regular assessment proceedings for cases involving transfer pricing adjustments (after the TPO order is passed) may still go through the faceless route. CBDT has notified specific exclusions from time to time, so check the latest notification to confirm the current position.

What if the DIN on my notice does not validate on the e-filing portal?

If the DIN does not validate, document this with screenshots immediately. File a written objection through e-Proceedings stating that the notice does not carry a valid DIN as mandated by CBDT Circular 19/2019 and is therefore non-est in law. Cite the relevant High Court decisions supporting this position. Do not ignore the notice entirely — always file a response on merits as well, without prejudice to your DIN objection, to protect your client's interests in case the DIN challenge is not accepted.

How does TaxNoticeAI handle notices that contain multiple queries across different assessment years?

TaxNoticeAI processes each notice as a separate case tied to a specific assessment year. If your client has received faceless assessment notices for multiple assessment years, upload each notice separately. The AI analyzes each one independently, though you can reference related cases when customizing your response. This ensures that the legal analysis and citations are specific to the relevant assessment year's facts and applicable law.

For guidance on other common notice types, see our detailed guides:

The faceless assessment system is here to stay, and CAs who master its mechanics will serve their clients more effectively. TaxNoticeAI is designed to handle the heavy lifting — DIN validation, legal research, response drafting, and deadline tracking — so you can focus on the strategic decisions that require professional judgment.

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TaxNoticeAI Team

Tax Law Research & AI Analysis

The TaxNoticeAI Research Team combines expertise in Indian tax law, AI, and legal technology to help Chartered Accountants respond to tax notices faster and with verified legal citations.

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Disclaimer: The information provided is for educational and informational purposes only and should not be construed as legal or tax advice. AI-generated content is a draft for professional review — always verify with applicable laws, circulars, and case law before filing. Consult a qualified Chartered Accountant or tax professional before acting on any information presented here.

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