Articles

The New Face of Faceless Assessments!!

Written by  2020-09-06   875

The New Face of Faceless Assessments!!

“Anonymity is the fame of the future.” - John Boyle O’ Reilly

1.1 Faceless assessments: A Paradigm Shift in tax administration!!

Well Yes Friends, FACELESS ASSESSMENTS have become a REALITY now…

Our Hon’ble PM Sh. Narendra Modi has launched a new platform for Transparent Taxation for ‘Honouring the Honest Taxpayers’, coining three new terms viz. Seamless, Painless & Faceless, for showcasing the perceived changed nature of the tax administration in India. The thrust of this taxation platform is on Faceless Assessments, Faceless Appeals and Taxpayers’ Charter.

It may be recollected that on 7-10-2019, delivering on the promise made to taxpayers in the budget speech of the Hon’ble Finance Minister, the ‘E-Assessment Scheme, 2019’ contemplating within its fold, the use of artificial intelligence, machine learning, algorithm based automated allocation system, automated examination tool and risk management functionalities, has been launched by the Hon’ble Revenue Secretary, with the inauguration of the National e-Assessment Centre (NeAC) in New Delhi.

In the first phase, the Income-tax department has selected 58,319 cases of regular assessments u/s 143(3), for AY 2018-19, for scrutiny under the new ‘E-Assessment Scheme, 2019’, on pilot basis and the remaining regular assessment cases for AY 2018-19, were being conducted in the traditional manner by the jurisdictional assessing authorities via e-Proceedings functionality, in the e-filing portal of the Income-tax department.

However, as usual, our Hon’ble PM Sh. Narendra Modi, going by his well-known image of initiating bold reforms and inducting surprise element in his policy announcements, has extended the coverage of the ‘E-Assessment Scheme 2019’ (now being renamed as the ‘Faceless Assessment Scheme, 2019), to all the regular assessments u/s 143(3) for the AY 2018-19, and to best judgement assessments u/s 144, and further to all pending income escaping assessments u/s 147 of the Income Tax Act, 1961, as well, w.e.f. 13.8.2020.

The assessments being covered under the new Faceless Assessment Scheme, 2019, are more popularly being referred to as the Faceless Assessments’ or the ‘Jurisdiction-less Assessments’. Let us understand, why these assessments are being referred so.

(a) Faceless Assessments: These assessments are being referred to as ‘Faceless’ simply because the assessee will not get to see the face of his/her assessing officer or in other words, the assessee will not be able to know as to who will conduct his/her assessments. The Faceless Assessments, completely eliminate the physical interface between the assessee and the assessing authority and instead involves the electronic interface right from the selection of the cases for the scrutiny purpose with the help of ‘automated allocation system’ involving therein an algorithm for randomised allocation of cases, by using suitable technological tools, including artificial intelligence and machine learning, with a view to optimise the use of resources, and the conduct of assessments exclusively in electronic mode via the ‘e-Proceedings’ utility of the e-Filing portal of Income-tax department’s website, and finally the review and examination of the assessment orders using ‘automated examination tool’ involving therein an algorithm for standardised examination of draft assessment orders, by using suitable technological tools, including artificial intelligence and machine learning, with a view to reduce the scope of discretion.

(b) Jurisdiction-less Assessments: These assessments are being referred to as ‘Jurisdiction-less’ because these are conducted by a Team/Group of Expert IT Officers at multiple-level assessment units viz. National e-Assessment Centre (NeAC), Regional e-Assessment Centre (ReAC), Verification Unit, Technical Unit and Review Unit, and shall not be conducted by an individual jurisdictional Assessing Officer. The cases shall be assigned by NeAC to an assessment unit in any ReAC based on ‘automated allocation system’ involving therein an algorithm for randomised allocation of cases, by using suitable technological tools, including artificial intelligence and machine learning and as such shall be location agnostic.

CBDT vide its Gazetted Notification S.O. 2745 dated 13.8.2020, have amended the "E-Assessment Scheme 2019", to provide that w.e.f. 13.8.2020, the "E-Assessment Scheme 2019", shall be termed as "Faceless Assessment Scheme 2019", and all E-Assessments shall be conducted as Faceless Assessments.

Further, CBDT vide its Order u/s 119 of the Income Tax Act  bearing F.No. 187/3/2020-ITA-I, dated 13.8.2020, have directed that in order to ensure that all assessment orders are passed through Faceless Assessment Scheme 2019, all the assessment orders shall hereafter be passed by National e-Assessment Centre (NeAC), through the Faceless Assessment Scheme 2019.

However, two exceptions have been provided and these are:

(i) Assessment orders in cases assigned to Central Charges (Block Assessment Cases u/s 153A/153C);

(ii) Assessment Orders in cases assigned to International Tax Charges.

It has also been stipulated in the CBDT order that any assessment order which is not in conformity with the Faceless Assessment Scheme 2019, shall be treated as non-est and shall be deemed to have never been passed.

1.2 Difference between old e-assessment scheme, 2019 & new faceless Assessment scheme, 2019

Consequent to the announcement of the new platform for transparent taxation by our Hon’ble PM, the Central Board of Direct Taxes (CBDT), in exercise of the powers conferred by section 143(3A) of the Income Tax Act, 1961, has issued its Gazetted Notification dated 13.8.2020, bearing F.No. S.O. 2745 (E), making certain crucial and significant amendments in the E-Assessment Scheme, 2019, notified by its earlier Gazetted Notification dated 12.9.2020, bearing F.No. S.O. 3264 (E).

Inspite of the much hype and hoopla doing the rounds in the media channels and newspapers, concerning the new taxation platform launched by our Hon’ble PM, ironically, the practicalities and nuances of these notified amendments in the E-Assessment Scheme, 2019, by CBDT, have been somehow, overlooked and ignored in the Tax Circles and by the assessees and taxpayers. So, for the ready reference of the worthy readers, the exact nature, significance and implications of these amendments in the E-Assessment Scheme, 2019, as notified by CBDT, are being discussed and analysed as under:

S. No.

Parameters

Old E-Assessment Scheme, 2019

New Faceless Assessment Scheme, 2019

1.

Nomenclature

E-Assessment Scheme, 2019

Faceless Assessment Scheme, 2019

2.

CBDT Notification

S.O. 3264 (E), dated 12.9.2019

S.O. 2745 (E), dated 13.8.2020

1.

Applicability

58,319 Regular Assessments under section 143(3), for AY 2018-19, selected on pilot basis.

(i) All Regular Assessments under section 143(3), for AY 2018-19;

(ii) All pending Income Escaping Assessments /Reassessments under section 147, as on 13.8.2020;

(iii) Best Judgement Assessments u/s 144.

3.

Applicability of Income Tax Rules, 1962

No specific mention of applicability.

Applicable to the Faceless Assessment Scheme 2019.

4.

Enlargement in Function of Technical Unit (TU)

Technical assistance on legal, accounting, forensic, information technology, valuation, transfer pricing, data analytics, management or other technical matters.

Technical assistance on audit in addition to legal, accounting, forensic, information technology, valuation, transfer pricing, data analytics, management or other technical matters.

5.

Enlargement in Scope & Coverage

E-Assessment Scheme 2019, covered only 58,399 regular assessments u/s 143(3), for AY 2018-19, on pilot basis.

By virtue of insertion of new clause (iii) in para 5. Procedure for assessment, the undermentioned cases are now being covered in Faceless Assessment Scheme, 2019,

“where the assessee –

(a) has furnished his return of income under section 139 or in response to a notice issued under subsection (1) of 142 or sub-section (1) of section 148; and a notice under sub-section (2) of section 143 has been issued by the Assessing Officer or the prescribed income-tax authority, as the case may be; or

(b) has not furnished his return of income in response to a notice issued under sub-section (1) of section 142 by the Assessing Officer; or

(c) has not furnished his return of income under sub-section (1) of section 148 and a notice under subsection (1) of section 142 has been issued by the Assessing Officer.

6.

Enabling Provision for undertaking Best Judgement Assessment/Exparte Assessment u/s 144 of the Income Tax Act, 1961.

There was no enabling provision in the E- Assessment Scheme, 2019, for undertaking best judgement assessment/exparte assessment u/s 144, in the situations of the failure of the assessee in responding to the scrutiny notices u/s 143(2) or 142(1), or with a direction issued u/s 142(2A).

An enabling provision has been specifically inserted in the new Faceless Assessment Scheme, 2019, for undertaking best judgement assessment/exparte assessment u/s 144, in the situations of the failure of the assessee in responding to the scrutiny notices u/s 143(2) or 142(1), or with a direction issued u/s 142(2A).

7.

Jurisdictional Unit for drafting Revised Draft Assessment Order

In the old E-Assessment Scheme, 2019, the Revised Draft Assessment Order, incorporating the suggested modifications by the Review Unit (RU), was also being prepared by the same Regional Assessment Unit (ReAC), which has prepared the original draft assessment order.

In the new Faceless Assessment Scheme, 2019, the Revised Draft Assessment Order, incorporating the suggested modifications by the Review Unit (RU), is to be prepared by a new Regional Assessment Unit (ReAC), selected by National e-Assessment Centre (NeAC) on random allocation basis, and not by the old ReAC, which has prepared the original draft assessment order. So, now, in the new scheme, two different ReACs may prepare the draft assessment orders.

8.

Power to Transfer Assessment Cases to the Jurisdictional Assessing Officer

In the old E-Assessment Scheme, 2019, the power to transfer assessment cases to the jurisdictional assessing officers, lies solely with the National e-Assessment Centre (NeAC).

In the new Faceless Assessment Scheme, 2019, the Principal Chief Commissioner or Principal Director General, NeAC, is authorised to transfer certain assessment cases to the jurisdictional assessing officers, only after getting the prior approval of the Board (CBDT). The situations and circumstances in which NeAC may transfer the assessment cases to the jurisdictional assessing officers, with the prior approval of CBDT, are yet to be notified by CBDT.

9.

Right of Personal Hearing by the Assessee

In the old E-Assessment Scheme, 2019, by virtue of a right vested in the scheme, the assessee was entitled to personal hearing, by way of video conferencing/telephony, in case of disagreement with the additions/disallowances proposed in the draft assessment order, in all assessment cases.

In the new Faceless Assessment Scheme, 2019, the assessee is not having any ‘by-default’ right of personal hearing and the assessee may only request for a personal hearing by way of video conferencing/telephony, in case of disagreement with the additions/disallowances proposed in the draft assessment order. The Chief Commissioner or the Director General, ReAC, may approve such request for personal hearing, if he is of the opinion that the case falls in the list of specified circumstances as notified by CBDT. The circumstances where the request of the assessee for personal hearing via video conferencing may be approved are yet to be notified by CBDT.

10.

Mode of Communications between the assessee and NeAC, ReAC, Technical Unit, Verification Unit and Review Unit

In the old E-Assessment Scheme, 2019, all communications between the assessee, NeAC, ReAC, Technical Unit, Verification Unit and Review Unit, were to be exchanged exclusively by electronic mode.

In the new Faceless Assessment Scheme, 2019, all communications between the assessee, NeAC, ReAC, Technical Unit and Review Unit, shall be exchanged exclusively by electronic mode. However, in the cases of enquiry or verification being conducted by the Verification Unit, in certain specified circumstances, yet to be notified by CBDT, the conventional means of communication, i.e. physical interface may be adopted. 

11.

Authentication of Electronic Record

In the old E-Assessment Scheme, 2019, the authentication/signing of the electronic record was to be done by affixing the digital signature, both by the assessee and the assessing authority i.e. NeAC.

In the new, Faceless Assessment Scheme, 2019, the authentication/signing of the electronic record has to be done by NeAC by affixing  its digital signature, and the assessee shall authenticate the electronic record by affixing his/her digital signature, in cases where the assessee is required under the Rules to furnish his/her return of income under digital signature and in any other cases, either by affixing digital signature or under the electronic verification code.

12.

Power to specify format, mode, procedure and processes

In the old E-Assessment Scheme, 2019, the Principal Chief Commissioner or the Principal Director General, NeAC, were vested with the power to specify format, mode, procedure and processes under the Scheme.

In the new, Faceless Assessment Scheme, 2019, the Principal Chief Commissioner or the Principal Director General, NeAC, are authorised to specify format, mode, procedure and processes under the Scheme, only with the prior approval of the Board (CBDT).

1.3 Difference between traditional e-proceedings assessments & new faceless assessments

In para 1.2 above, we have analysed and understood the points of distinction between the Old E-Assessment Scheme, 2019 and the New Faceless Assessment Scheme, 2019. However, for better and clear understanding of the worthy readers, it is also essential and desirable to know the distinction between the traditional e-assessments conducted via e-Proceedings functionality of the e-Filing portal of the Income-tax department and the new faceless assessments being conducted under the Faceless Assessment Scheme, 2019. Thus, for ready reference, these points of distinction are being tabulated as under:

S. No.

Particulars

Conventional Assessments via e-Proceedings

Faceless Assessments under Faceless Assessment Scheme, 2019

1.

Applicability

Regular Assessments under section 143(3)

(i) Regular Assessments under section 143(3);

(ii) Reassessments under section 147;

(iii) Best Judgement Assessments u/s 144.

2.

Assessment Year

Till AY 2017-18

From AY 2018-19 onwards for All Regular Assessments and w.e.f. 13.8.2020, for all pending Re-Assessments.

3.

Assessing Authority

Jurisdictional Assessing Officer

National e-Assessment Centre (NeAC)

4.

Notice under section 143(2) Issuing Authority

Jurisdictional Assessing Officer

National e-Assessment Centre (NeAC)

5.

Reply Period of Notice under section 143(2)

As specified in the Notice under section 143(2)

Within 15 days from the date of receipt of such Notice under section 143(2)

6.

Assignment of Case

Jurisdictional Assessing Officer

The NeAC assigns the case to a specific assessment unit in any one Regional e-Assessment Centre through an automated allocation system.

7.

Inquiries during the course of assessment proceedings

Jurisdictional Assessing Officer Issues Notices/Questionnaires under section 142(1) of the Act.

The NeAC may issue appropriate notice or requisition u/s 142(1), to the assessee for obtaining any further information, documents or evidence as required by the assessment unit in the Regional e-Assessment Centre, to which the case has been assigned by the NeAC.

8.

Provision of Draft Assessment Order

Only applicable in the Cases of References to Transfer Pricing Officers (TPO) resulting in Variation and Foreign Companies passed by the Jurisdictional Assessing Officers

Applicable in all assessments under section 143(3) of the Act. Draft Assessment Orders are passed by the assessment unit in the Regional e-Assessment Centre, to which the case has been assigned by the NeAC.

9.

Action on Draft Assessment Order

Not Applicable

The NeAC shall examine the draft assessment order in accordance with the risk management strategy specified by the Board, including by way of an automated examination tool, whereupon it may decide to:

   (a)   finalise the assessment as per the draft assessment order and serve a copy of such order and notice for initiating penalty proceedings, if any, to the assessee, along with the demand notice, specifying the sum payable by, or refund of any amount due to, the assessee on the basis of such assessment; or

   (b)   provide an opportunity to the assessee, in case a modification is proposed, by serving a notice calling upon him to show cause as to why the assessment should not be completed as per the draft assessment order; or

    (c)   assign the draft assessment order to a review unit in any one Regional e-Assessment Centre, through an automated allocation system, for conducting review of such order.

10.

Final Assessment Order

Passed by the Jurisdictional Assessing Officer after considering the written and verbal submissions of the assessees.

The NeAC sends all the e-replies and submissions of the assessee containing the justification for revision of the draft assessment order to the regional assessment unit for revision of the draft assessment order.

 

 

 

In the cases, where no objections are filed by the assessees, the NeAC finalises the assessment based on the Draft Order only.

Upon receiving the Revised Draft Assessment Order, the NeAC may:

    (i)   in case no modification prejudicial to the interest of the assessee is proposed, finalise the assessment based on such revised draft assessment order; or

   (ii)   in case modification prejudicial to the interest of the assessee is proposed, an opportunity of personal hearing by way of video telephony only may be provided to the assessee, and based on the response of the assessee, the same procedure of revision and finalization is to be followed and Final Assessment Order is then passed by the NeAC.

11.

Mode of Interface between the Assessee and the Assessing Authority

Electronic Mode via the ‘e-Proceedings’ functionality in the ITBA Module. However, after serving the Show Cause Notice, an opportunity of Personal Hearing to the assessee involving physical interface between the assessee and the jurisdictional AO is to be provided. However, practically there was no bar on physical interface between the assessee and the jurisdictional assessing officer.

Electronic Mode via the ‘e-Proceedings’ functionality in the ITBA Module. However, after serving the Show Cause Notice, an opportunity of Personal Hearing to the assessee via video telephony only may be provided to the assessee in certain specified circumstances

1.4 The Functional Classification of the different Assessment Units in the new ‘Faceless Assessment Scheme, 2019 Ecosystem’ is presented as under:

Source: Income Tax Department

Faceless Assessment Scheme, 2019: PAN India Presence

Source: Income Tax Department

Faceless Assessment Scheme, 2019: Organisational Structure

Source: Income Tax Department

Source: Income Tax Department

1.5 Procedure for Faceless Assessments

For easy and better understanding of the worthy readers, the above stated procedure of ‘Faceless Assessments proceedings as per the new ‘Faceless Assessment Scheme, 2019’ is being explained diagrammatically as under:

Diagrammatic Presentation of Faceless Assessment Scheme, 2019

(1) The assessment under this Scheme shall be made as per the following procedure, namely:

(i) the National e-Assessment Centre shall serve a notice on the assessee under sub-section (2) of section 143, specifying the issues for selection of his case for assessment;

(ii) the assessee may, within fifteen days from the date of receipt of notice referred to in clause (i), file his response to the National e-assessment Centre;

(iii) where the assessee –

(a) has furnished his return of income under section 139 or in response to a notice issued under subsection (1) of 142 or sub-section (1) of section 148; and a notice under sub-section (2) of section 143 has been issued by the Assessing Officer or the prescribed income-tax authority, as the case may be; or

(b) has not furnished his return of income in response to a notice issued under sub-section (1) of section 142 by the Assessing Officer; or

(c) has not furnished his return of income under sub-section (1) of section 148 and a notice under subsection (1) of section 142 has been issued by the Assessing Officer; the National e-Assessment Centre shall intimate the assessee that assessment in his case shall be completed under this Scheme;

(iv) the National e-assessment Centre shall assign the case selected for the purposes of e-assessment under this Scheme to a specific assessment unit in any one Regional e-assessment Centre through an automated allocation system;

(v) where a case is assigned to the assessment unit, it may make a request to the National e-assessment Centre for

(a) obtaining such further information, documents or evidence from the assessee or any other person, as it may specify;

(b) conducting of certain enquiry or verification by verification unit; and

(c) seeking technical assistance from the technical unit;

(vi) where a request for obtaining further information, documents or evidence from the assessee or any other person has been made by the assessment unit, the National e-assessment Centre shall issue appropriate notice or requisition to the assessee or any other person for obtaining the information, documents or evidence requisitioned by the assessment unit;

(vii) the assessee or any other person, as the case may be, shall file his response to the notice referred to in clause (vi), within the time specified therein or such time as may be extended on the basis of an application in this regard, to the National e-Assessment Centre;

(viii) where a request for conducting of certain enquiry or verification by the verification unit has been made by the assessment unit, the request shall be assigned by the National e-assessment Centre to a verification unit in any one Regional e-assessment Centres through an automated allocation system;

(ix) where a request for seeking technical assistance from the technical unit has been made by the assessment unit, the request shall be assigned by the National e-assessment Centre to a technical unit in any one Regional e-assessment Centres through an automated allocation system;

(x) the National e-assessment Centre shall send the report received from the verification unit or the technical unit, based on the request referred to in clause (viii) or (ix) to the concerned assessment unit;

(xi) where the assessee fails to comply with the notice referred to in clause (vi) or notice issued under subsection (1) of section 142 or with a direction issued under sub-section (2A) of section 142, the

National e-Assessment Centre shall serve upon such assessee a notice under section 144 giving him an opportunity to show-cause, on a date and time to be specified in the notice, why the assessment in his case should not be completed to the best of its judgment;

(xii) the assessee shall, within the time specified in the notice referred to in clause (xi) or such time as may be extended on the basis of an application in this regard, file his response to the National e-Assessment Centre;

(xiii) where the assessee fails to file response to the notice referred to in clause (xi) within the time specified in the notice or within the extended time, if any, the National e-Assessment Centre shall intimate such failure to the assessment unit;

(xiv) the assessment unit shall, after taking into account all the relevant material available on the record make in writing, a draft assessment order or, in a case where intimation referred to in clause (xiii) is received from the National e-Assessment Centre, make in writing, a draft assessment order to the best of its judgment, either accepting the income, or sum payable by, or sum refundable to, the assessee as per his return or modifying the said income or sum, and send a copy of such order to the National e-assessment Centre;

(xv) the assessment unit shall, while making draft assessment order, provide details of the penalty proceedings to be initiated therein, if any;

(xvi) the National e-assessment Centre shall examine the draft assessment order in accordance with the risk management strategy specified by the Board, including by way of an automated examination tool, whereupon it may decide to, —

(a) finalise the assessment as per the draft assessment order and serve a copy of such order and notice for initiating penalty proceedings, if any, to the assessee, along with the demand notice, specifying the sum payable by, or refund of any amount due to, the assessee on the basis of such assessment; or

(b) provide an opportunity to the assessee, in case a modification is proposed, by serving a notice calling upon him to show cause as to why the assessment should not be completed as per the draft assessment order; or

(c) assign the draft assessment order to a review unit in any one Regional e-assessment Centre, through an automated allocation system, for conducting review of such order;

(xvii) the review unit shall conduct review of the draft assessment order, referred to it by the National e-assessment Centre whereupon it may decide to, —

(a) concur with the draft assessment order and intimate the National e-assessment Centre about such concurrence; or

(b) suggest such modifications, as it may deem fit, to the draft assessment order and send its suggestions to the National e-assessment Centre;

(xviii) the National e-assessment Centre shall, upon receiving concurrence of the review unit, follow the procedure laid down in sub-clause (a) or sub-clause (b) of clause (xvi), as the case may be;

(xix) the National e-assessment Centre shall, upon receiving suggestions for modifications from the review unit, assign the case to an assessment unit, other than the assessment unit which has made the draft assessment order, through an automated allocation system;

(xx) the assessment unit shall, after considering the modifications suggested by the review unit, send the final draft assessment order to the National e-assessment Centre;

(xxi) The National e-assessment Centre shall, upon receiving final draft assessment order, follow the procedure laid down in sub-clause (a) or sub-clause (b) of clause (xvi), as the case may be;

(xxii) the assessee may, in a case where show-cause notice under sub-clause (b) of clause (xvi) has been served upon him, furnish his response to the National e-assessment Centre on or before the date and time specified in the notice or within the extended time, if any;

(xxiii) the National e-assessment Centre shall,-

(a) in a case where no response to the show-cause notice is received, finalise the assessment as per the draft assessment order, as per the procedure laid down in sub-clause (a) of clause (xvi); or

(b) in any other case, send the response received from the assessee to the assessment unit;

(xxiv) the assessment unit shall, after taking into account the response furnished by the assessee, make a revised draft assessment order and send it to the National e-assessment Centre;

(xxv) the National e-assessment Centre shall, upon receiving the revised draft assessment order,—

(a) in case no modification prejudicial to the interest of the assessee is proposed with reference to the draft assessment order, finalise the assessment as per the procedure laid down in sub-clause (a) of clause (xvi); or

(b) in case a modification prejudicial to the interest of the assessee is proposed with reference to the draft assessment order, provide an opportunity to the assessee, by serving a notice as per the procedure laid down in sub-clause (b) of clause (xvi);

(c) the response furnished by the assessee shall be dealt with as per the procedure laid down in clauses (xxii), (xxiii), and (xxiv);

(xxvi) The National e-assessment Centre shall, after completion of assessment, transfer all the electronic records of the case to the Assessing Officer having jurisdiction over the said case for such action as may be required under the Act;”

(2) Notwithstanding anything contained in sub-paragraph (1), the Principal Chief Commissioner or the Principal Director General, in charge of National e-assessment Centre, may at any stage of the assessment, if considered necessary, transfer the case to the Assessing Officer having jurisdiction over such case, with the prior approval of the Board.”

1.6 Concluding Remarks

‘Self-reform automatically brings about social reform.’- Ramana Maharshi.

In order to make this path-breaking, radical and revolutionary initiative of the ‘faceless’ and ‘jurisdiction-less’, ‘e-Assessments’ effective and taxpayer friendly, it is essential and crucial to issue appropriate clarifications with regard to the exact modus operandi of the functionality of such faceless assessments and to take suitable measures and steps to overcome the initial bottlenecks and hurdles by way of ensuring the commensurate and supporting IT infrastructure to enable seamless and smooth data transfer, incorporating standardization in the conduct of assessments by assessing authorities by implementing Standard Operating Procedures (SOPs) to do away with the subjective-ness and arbitrariness in making additions and disallowances in ‘Faceless Assessments’ and fixing proper and effective accountability in cases of high pitched assessments.

Clearly, the faceless assessment’s process needs to be implemented in a very careful and thoughtful manner, considering the reality of complicated and ever dynamic business transactions.

So, all the stakeholders involved i.e. the taxpayers, the tax professionals, the assessing authorities, the regulatory body CBDT, the Finance Ministry and the Government should embrace this radical, revolutionary and path-breaking reform of ‘faceless assessments’ in good and positive spirits and should work collectively and cohesively to make this initiative a grand success.

It is only then perhaps the Faceless Assessment will really live up to its true potential, and taxpayers as well as the tax administration authorities will reap the benefits that it is supposed to provide.

‘The only thing which is constant is the change!!’

Useful Reference: For More Details and Complete Understanding of the nitty-gritties and nuances of the New “Faceless Assessments Scheme, 2019”, the recently published Book titled “Faceless Assessment Ready Reckoner with Real Time Case Studies ”, authored by the author of this article Sh. Mayank Mohanka, FCA, and published by Taxmann Publications, may be referred, which is a ready reckoner and a referencer and user manual to help and assist the assessees and the assessing authorities in their ‘faceless assessment pursuits’. An honest and sincere effort has been made in this Book to explain and demonstrate the practical aspects and nitty-gritties of ‘faceless assessments’ in a ‘step-by-step-manner’ through ‘real-time practical case studies’ encompassing crucial and significant scrutiny issues having immense relevance and practical utility for all the assesses and the assessing authorities. The manner and practical aspects of ‘e-filing of Rectification Application’ u/s 154 of the Act and ‘e-filing of Responses against the outstanding Income Tax demand have also been explained and demonstrated in a ‘step-by-step’ manner.

This Book characterizes a ‘natural blend of law and practice’ concerning the New “Faceless Assessments Scheme, 2019”, and also includes the Country-specific Best International Practices in Tax Administration and the measures taken up by the Indian Tax Administration Authorities to ramp up the effectiveness and efficiency of the governance levels and to transform into a ‘digitally mature’ tax administration.

                            “व्यये कृते वर्धते नित्यं | विद्या धनं सर्वे धनं प्रधानम् ||”

           Knowledge multiplies manifold by sharing. It is a supreme form of wealth.

                                                                                                                                     Warm Regards

                                                                                                                                   Mayank Mohanka