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TMI BlogFaceless Assessment: Decoding the Exemptions for International Tax ChargesX X X X Extracts X X X X X X X X Extracts X X X X ..... INTRODUCTION This article delves into a pivotal legal question concerning the validity of reassessment proceedings under the Income Tax Act, 1961. Specifically, it examines whether show cause notices issued u/s 148 in matters relating to international tax charges are exempted from following the statutory faceless procedure. The case revolves around the interpretation of Section 144B, Section 15 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 29.03.2022, Section 144B(2), and the CBDT order dated 06.09.2021 exempts international tax charges from the faceless procedure. * The CBDT order specifically excludes assessment orders in cases assigned to international tax charges from the faceless regime. * The petitioners, being Non-Resident Indians (NRIs), are not covered by the faceless scheme, which is applicable only to residents. COUR ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... td. and upheld the literal interpretation of the provisions. * The Court relied on the principle established by Lord Simonds and followed by the Indian Supreme Court, which emphasizes adhering to the natural meaning of the statutory language. ANALYSIS AND DECISION The Court concluded that the respondents erred in not following the mandatory faceless procedure prescribed in the scheme dated 29. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , accountability, and efficiency in tax administration. The Court's emphasis on the mandatory nature of the faceless procedure, even in cases involving international tax charges, highlights the importance of upholding statutory mandates and ensuring uniform application of the law. This case contributes to the evolving jurisprudence surrounding the faceless assessment scheme and clarifies the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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