Section 144B Faceless Assessment: 12 High Court Rulings (2026)
A structured index of 12 High Court rulings on Section 144B faceless assessment orders, covering procedural challenges across India, January–April 2026.
This compilation indexes twelve High Court orders — decided between January 2026 and April 2026 — in which assessees challenged assessment orders, notices, or related proceedings under or in connection with Section 144B of the Income Tax Act, 1961. The rulings span the Gauhati, Bombay, Gujarat, Madras, Telangana, Orissa, and Karnataka High Courts, and collectively reflect the range of procedural and jurisdictional questions that have arisen in the context of the National Faceless Assessment Centre's operations. The compilation is intended for use by in-house tax teams, Big-4 associates, and law firm researchers who require a structured reference index of recent judicial activity on this provision.
Research index only. This page summarises publicly available court orders for research and tracking purposes. Nothing here constitutes legal advice, tax advice, or a recommendation of any course of action. Always verify against the full judgment text and check for subsequent stays, reversals, or appeals before relying on any ruling.
The statutory framework in one paragraph
Section 144B of the Income Tax Act, 1961, introduced with effect from 1 April 2021, provides the procedural framework governing faceless assessments conducted through the National Faceless Assessment Centre (NFAC) and its Assessment Units. The section prescribes the manner in which notices are to be issued, responses are to be received, draft assessment orders are to be prepared, show-cause notices are to be served before any variation is proposed, and final assessment orders are to be passed — all through an electronic, jurisdiction-free mechanism. Sub-sections set out, among other things, the requirement to grant a personal hearing in specified circumstances and the conditions under which the faceless assessment scheme applies alongside or in lieu of the ordinary assessment procedure under the Act.
The 12 rulings
1. Assam Cricket Association vs The Union Of India And 3 Ors
- Bench: Gauhati High Court
- Date: 30 April 2026
- Sections engaged: 11, 143(3), 144B, 2(15), 246A, 251
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal was filed as WP(C)/2254/2026 before the Gauhati High Court, with the Assam Cricket Association challenging proceedings that engaged sections relating to exemption, scrutiny assessment, and faceless assessment. Per the source preview, the matter was heard on 30 April 2026, with senior counsel appearing for the petitioner association and Standing Counsel for the Income Tax Department; the substantive disposal is not captured in the available preview.
2. Wrode And Wire Pvt.Ltd vs National Faceless Assessment Centre
- Bench: Bombay High Court
- Date: 24 April 2026
- Sections engaged: 143(3), 144B, 144B(7)(vii)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The writ petition (WP No. 3533 of 2022) challenged the assessment order dated 12.01.2022 passed under Section 143(3) read with Section 144B for Assessment Year 2018-19, along with the Notice of Demand and consequential penalty notices. Per the source preview, the petitioner is a company that had filed its return of income declaring a total income of Rs. 6,19,860/- for Assessment Year 2018-19, and the case was taken up for scrutiny; the rule was made returnable forthwith and heard finally with respondents waiving service.
3. Darshan Navinchandra Kuriya vs National E Assessment Centre
- Bench: Gujarat High Court
- Date: 20 April 2026
- Sections engaged: 147, 144B
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal was filed as R/Special Civil Application No. 4163 of 2026 before the Gujarat High Court at Ahmedabad, engaging provisions relating to income escaping assessment and faceless assessment. Per the source preview, the matter was taken up for final hearing and final disposal on the same day with the consent of advocates appearing for both sides, and the rule was made returnable forthwith with the respondent's counsel waiving service of notice.
4. Palani.S vs The Additional / Joint / Deputy /
- Bench: Madras High Court
- Date: 20 April 2026
- Sections engaged: 148, 147, 144B
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The writ petition (W.P. No. 15325 of 2023) was filed under Article 226 of the Constitution of India seeking a writ of certiorari to quash the notice issued under Section 148 bearing reference ITBA/AST/S/148_1/2021-22/1042372435(1) dated 31.03.2022 and the consequential order under Section 147 read with Section 144B bearing reference ITBA/AST/S/147/2022-23/1050428865(1) dated 06.03.2023 for Assessment Year 2018-2019, on the ground that the said notice and order were illegal, without jurisdiction, and not in accordance with law; the petition is filed in relation to PAN: AKCPP4859N.
5. Sanjay Mahendrabhai Desai vs National E-Assessment Centre
- Bench: Gujarat High Court
- Date: 7 April 2026
- Sections engaged: 144B(6)(vii), 144B
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal was filed as R/Special Civil Application No. 3773 of 2026 before the Gujarat High Court at Ahmedabad, with the controversy relating to faceless assessment and the provisions of Section 144B including sub-section 144B(6)(vii). Per the source preview, the matter was taken up for final hearing and final disposal on the same day with the consent of the advocates for both parties, and the rule was made returnable forthwith with the respondents' counsel waiving service.
6. Hansgrohe India Private Limited vs The Assessment Unit Income Tax Dept And
- Bench: Bombay High Court
- Date: 25 March 2026
- Sections engaged: 144B, 144C
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The writ petition (WP No. 3501 of 2026) challenged the final assessment order dated 2nd February 2026 passed under Section 143(3) read with Section 144B for Assessment Year 2023-24. Per the source preview, the petitioner's grievance was that, as an "eligible assessee" under Section 144C(15)(b)(i), the Assessing Officer was required to first pass a draft assessment order and serve it so as to enable the petitioner to file objections before the Dispute Resolution Panel before any final assessment order prejudicial to the assessee's interest could be passed.
7. M/S.Meghana Avenues Private Limited vs The Commissioner Of Income Tax
- Bench: Telangana High Court
- Date: 5 March 2026
- Sections engaged: 105, 144, 144B, 147, 269S, 271(1)(c), 271D, 271D(2), 274
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The writ petition (WP No. 24403 of 2025) raised the question whether penalty proceedings under Section 271D could be initiated on the basis of satisfaction recorded by the Joint Commissioner on perusal of assessment records, rather than by the assessing officer. Per the source preview, the challenge was to the order of the National Faceless Appeal Centre (NFAC) dated 04.06.2025 for Assessment Year 2017-18, which upheld the National Faceless Assessment Centre's order dated 19.10.2022 imposing a penalty of Rs. 40,50,000/- under Section 271D read with Section 274.
8. Jsw Steel Coated Products Limited vs National Faceless Assessment Centre
- Bench: Bombay High Court
- Date: 4 March 2026
- Sections engaged: 143(3), 144B
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The writ petition (WP No. 2492 of 2024) challenged the assessment order dated 23.03.2024 passed under Section 143(3) read with Section 144B for Assessment Year 2022-23, along with the Notice of Demand dated 23.03.2024 and a Penalty Notice of the same date. Per the source preview, the ground of challenge included that the impugned notices were issued and the assessment order was passed in the name of a non-existent entity; the rule was made returnable forthwith and heard finally with respondents waiving service.
9. M/S. Sanjay Kumar Bijay Kumar vs Principal Commissioner Of Income Tax-I
- Bench: Orissa High Court
- Date: 24 February 2026
- Sections engaged: 144B, 147, 148, 148A(1), 148A(3), 148A(b), 44A
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The writ petition (W.P.(C) No. 28067 of 2025) was filed before the Orissa High Court at Cuttack under Articles 226 and 227 of the Constitution of India. Per the source preview, the matter pertains to PAN: ABAFS4271L for Assessment Year 2019-20, and involves a notice bearing DIN & Notice No. ITBA/AST/F/148A/2025-26/1077734077(1); the petition raises challenges engaging reassessment provisions alongside faceless assessment procedure.
10. Sanjay Harichand Chugh vs Assessment Unit
- Bench: Karnataka High Court
- Date: 18 February 2026
- Sections engaged: 143(3), 144B
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The writ petition (WP No. 5019 of 2026) was filed under Articles 226 and 227 of the Constitution of India before the Karnataka High Court at Bengaluru, praying to quash the assessment order under Section 143(3) read with Section 144B dated 02.03.2024 bearing DIN No. ITBA/AST/S/143(3)/2023-24/1061898649(1) for Assessment Year 2022-23. Per the source preview, the petition proceeded to hearing with a Senior Advocate appearing for the petitioner and Standing Counsel for the respondents.
11. Tanaji Appasaheb Suryavanshi vs The Income Tax Officer
- Bench: Karnataka High Court
- Date: 27 January 2026
- Sections engaged: 143(3), 144B, 272A
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The writ petition (WP No. 109407 of 2025) was filed before the Karnataka High Court at Dharwad under Articles 226 and 227 of the Constitution of India, praying for a writ of certiorari to quash the order passed under Section 143(3) read with Section 144B dated 22/09/2022 bearing DIN ITBA/AST/S/143(3)/2022-23/1045835891(1) issued by the National Faceless Assessment Centre for Assessment Year 2020-21. Per the source preview, the matter was listed for preliminary hearing at the time of the available preview.
12. Sashank Sekhar Pradhan vs The Principal Chief Commissioner Of
- Bench: Orissa High Court
- Date: 22 January 2026
- Sections engaged: 142(1), 144B, 148, 148A, 151A
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The writ petition (W.P.(C) No. 37496 of 2025) challenged the order dated 25th March 2023 passed under Section 148A and the connected notice dated 27th March 2023 under Section 148, issued by the Deputy Commissioner of Income Tax Officer Circle-1(1), Bhubaneswar. Per the source preview, the petitioner's counsel argued that the said order and notices were without jurisdiction and authority in law as they were beyond the scope of Section 151A read with Section 144B, with reference also made to a Ministry of Finance notification dated 29th March 2022 on e-assessment of income escaping assessment.
Patterns across these 12 rulings
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Writ petitions as the dominant challenge route. Across all twelve cases, assessees approached High Courts under Articles 226 and/or 227 of the Constitution of India, rather than exhausting appellate remedies under the Act alone. This reflects a consistent litigation posture of challenging Section 144B-linked orders directly before High Courts on grounds of jurisdiction, procedure, or statutory non-compliance.
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National Faceless Assessment Centre as a recurring respondent. The National Faceless Assessment Centre (NFAC) or its Assessment Unit appears as a respondent in the majority of these cases, underscoring that the institutional design of the faceless regime is itself a frequent subject of judicial scrutiny rather than only the substantive tax additions made thereunder.
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Conjunction with reassessment provisions. Several cases (cases 4, 9, and 12 per the source previews) involve Section 144B alongside reassessment-related provisions, indicating that questions of jurisdiction and procedure in the post-Finance Act 2021 reassessment framework are being litigated together with the faceless assessment machinery.
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Multiple High Courts engaged simultaneously. The twelve rulings span seven different High Courts — Gauhati, Bombay, Gujarat, Madras, Telangana, Orissa, and Karnataka — indicating that Section 144B-related challenges are geographically widespread and not concentrated in any single jurisdiction.
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Eligibility for draft assessment order as a discrete ground. Case 6 (Hansgrohe India) illustrates a specific and distinct sub-issue: whether an assessee qualifying as an "eligible assessee" under the transfer pricing / international transaction provisions was entitled to a draft assessment order before a final order prejudicial to its interests was passed, reflecting that the interaction between Section 144B and Section 144C generates its own layer of procedural challenge.
How to use this compilation
This index is a starting point for identifying relevant judicial activity on Section 144B. Researchers should retrieve the full text of each judgment from indiankanoon.org, the respective High Court's official portal, or a licensed database before drawing any conclusions about the ratio, the final operative order, or the precise grounds on which any writ was admitted, disposed of, or dismissed. The available source previews for all twelve cases in this compilation do not contain the operative portion of the orders, and the outcome field records "Outcome not specified in source" for every entry — meaning the dispositive direction of each ruling must be independently verified.
When using these citations in legal submissions or internal memoranda, verify whether the order has been stayed, reversed, or appealed to a higher forum. High Court orders at the writ stage are frequently interim in nature, and a final disposal in the same proceedings, or an appeal to the Supreme Court, may have supervened. Researchers should also cross-check any CBDT circulars, instructions, or notifications issued in relation to the faceless assessment scheme that may bear on the procedural grounds raised in a particular case.
This compilation does not purport to be exhaustive. The cases indexed here represent a subset of Section 144B-related High Court activity within the January–April 2026 window drawn from the TaxNoticeAI corpus. Researchers conducting comprehensive due diligence should supplement this index with searches on official court portals and other structured legal databases covering the same period.
Source
All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.
Rangoli Bansal
Editorial Reviewer & CA Finalist
CA Finalist (ICAI), B.Com (Hons.) Delhi University. 7+ years across audit, internal controls, SOX 404, ICFR, RCSA, and GRC. Hands-on experience with GST and income-tax compliance filings, statutory audit, and internal audit. Editorial reviewer for TaxNoticeAI's case-law content.
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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