Gedda Krishnaveni Vs National Faceless Assessment Centre

GEDDA KRISHNAVENI, W/O BHASKARA RAO, AGED 38 YEARS, OCC COMMISSION AGENT, JONNADA, VILLAGE, DENKADA MANDALAM, VIZIANAGARAM DISTRICT - 535005, ANDHRA PRADESH.

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...PETITIONER

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AND

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NATIONAL FACELESS ASSESSMENT CENTRE, DELHI, MINISTRY OF FINANCE, ROOM NO.401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI-110003.

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INCOME TAX OFFICER, WARD-1, VIJAYANAGARAM, INCOME TAX OFFICE, KOPPU GUARANA BUILDING, SIDDARTHA NAGAR, VIZIANAGARAM - 535002, ANDHRA PRADESH.

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...RESPONDENT(S):

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Petition under Article 226 of the Constitution of India praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased topleased to issue a writ, order or direction, more particularly one in the nature of Writ of Mandamus, declaring the notice u/s 148 dated 03.04.2022 vide DIN No. ITBA/AST/S/148 1/2022- 23/1042457821(1) issued by the JAO (Respondent No.2) instead of Respondent No.1/(FAO) for A.Y.2018-19 as void, illegal and contrary to the provisions of Income-tax Act

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2

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RRR,J & TCDS,J W.P.No.2575 of 2026

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and contrary to the Constitutional Provisions including Principles of Natural Justice and pass

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IA NO: 1 OF 2026

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Petition under Section 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased Pleased to stay all further proceedings pursuant to the notice u/s 148 dated 03.04.2022 vide DIN No. ITBA/AST/S/148_172022-23/1042457821(1) issued by the JAO (Respondent No.2) instead of Faceless Assessing Officer (FAO) for A.Y.2018-19, pending disposal of the subject writ petition and pass

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Counsel for the Petitioner:

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1.G V N HARI

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Counsel for the Respondent(S):

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1.ANUP KOUSHIK KARAVADI

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RRR,J & TCDS,J W.P.No.2575 of 2026

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The Court made the following Order: (per Hon’ble Sri Justice R. Raghunandan Rao)

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The assessment of the petitioner, under the Income Tax Act, 1961, (herein referred to as ‘the Act’) for the assessment year, 2018-2019, was initiated, by way of a Notice under Section 148 of the Act, dated 03.04.2022, by the Jurisdictional Assessing Officer. This assessment resulted in an order of assessment, dated 20.12.2023. Aggrieved by the same, the petitioner had approached the Appellate Authority, who dismissed the Appeal, on 26.11.2025.

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Thereafter, the petitioner has approached this Court, by way of the present Writ Petition, with the contention that, the assessment proceedings are without jurisdiction, in view of Section 151A of the Act, which requires assessments of this nature to be carried out, under the faceless systems.

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A Division Bench of this Court in the case of Prameela Pasumarthi Vs.

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CIT¹ and following the judgments of various other Hon’ble High Courts, had held that, any assessment initiated by issuance of notices, by the Jurisdictional Assessing Authority, would be violative of the mandatory provisions of Section 151A of the Act, in as much as the said provision mandates that all such assessments should only be initiated and completed through the faceless systems.

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Following the said judgment, this Writ Petition is allowed, setting aside the notice, dated 03.04.2022, issued by the 2^nd respondent and all

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1 2025 SCC Online AP 4052

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RRR,J & TCDS,J W.P.No.2575 of 2026

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consequential proceedings. However, it shall be open to the respondent authorities to initiate and complete assessment, in accordance with Law. There shall be no order as to costs.

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As a sequel, pending miscellaneous applications, if any, shall stand closed.

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________________________

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R. RAGHUNANDAN RAO, J

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_________________

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T.C.D. SEKHAR, J

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Date:03.02.2026 KPV