Faceless Assessment Appeals & Penalty – Law | Procedure | Practical Guide is a practitioner's reference on India's faceless tax regime as it stands after the Finance Act, 2026. It covers faceless assessments, faceless first appeals (CIT(A) and JCIT(A)), faceless penalty proceedings, and allied e-schemes including verification, valuation, jurisdiction, escaping assessment, advance rulings, rectification, and dispute resolution.
Present Publication: 2nd Edition | 2026, amended by the Finance Act, 2026
Author: Adv. Kinjal Bhuta
Key Features
- Dual-Statute Mapping: Provision-wise comparative tables linking every section, rule, and form of the Income-tax Act, 1961/Rules 1962 with the Income-tax Act 2025/Rules 2026.
- Finance Act 2026 Penalty Amendments: Dedicated treatment of key penalty amendments and the new crypto-asset reporting penalty regime.
- Common Assessment-and-Penalty Order: Coverage of the regime introduced by the Finance Act 2025 for orders passed after 1 April 2027.
- Internal CBDT SOPs Decoded: Reproduction and question-by-question decomposition of the SOPs of the Assessment, Verification, Technical, Review, Penalty, and Penalty Review Units.
- FAQ Treatment of Every Scheme: Separate Q&A blocks covering the major Faceless and e-Proceedings schemes.
- Annotated Portal Walkthroughs: Step-by-step guidance covering response windows, attachment rules, partial and full responses, adjournments, e-verification, video-conference scheduling, and Form 99 (Form 35) appeal filing.
- Procedural Maps: Bird's-eye-view diagrams tracing cases through the faceless pipeline and communication flow between AU, VU, TU, RU, and NaFAC.
- Original Practitioner Survey: Survey of 25 senior practitioners covering their experience with faceless practice.
- Drafting Curriculum: Framework based on the 'A, B, C' principles – Accuracy, Brevity, and Clarity.
- Specimen Drafts Across the Lifecycle: Templates for grounds of appeal, statements of facts, condonation of delay, affidavits, additional evidence, stay applications, and assessment and appellate submissions.
- Fifteen Worked Case Scenarios: Practical specimen submissions covering recurring issues in scrutiny, re-assessment, natural justice, additions, and penalty proceedings.
- Sixteen Procedural Infirmities Digested: Issue-wise case-law digest covering reasonable opportunity, video-conference denial, non-speaking orders, adjournments, cross-examination, document access, and other procedural issues.
- Doctrines of Construction and Precedent: Coverage of important principles of statutory and judicial interpretation, supported by leading authorities.
- AI in Legal Drafting: Practical framework covering responsible use of generative AI, citation verification, factual accuracy, and drafting risks.
- Five Source-Document Appendices: Reproduction of the Faceless Assessment SOP, Faceless Appeal and e-Appeal Schemes, Faceless Penalty Scheme, other Faceless/e-Schemes, and relevant Press Releases.
- Palkhivala Anchors: Each chapter opens with a curated quotation from Sr. Adv. Nani Palkhivala.
Coverage of the Book
- Architectural Foundations: Constitutional, statutory, and administrative framework of faceless tax proceedings.
- Four Iterations of the Assessment Regime: Comparison of the Faceless Assessment Scheme 2019, New Faceless Regime from 1 April 2021, substituted regime from 1 April 2022 to 31 March 2026, and Income-tax Act 2025 framework.
- Faceless First Appeals: Appeals before JCIT(A) and CIT(A), including filing, additional grounds and evidence, enhancement, transfer, rectification, and progression to ITAT.
- Faceless Penalty Proceedings: Initiation, show-cause stage, immunity, waiver, reasonable-cause defence, common assessment-and-penalty orders, and applicable time limits.
- Thirteen Portal-Level Concerns: Practical issues relating to attachment limits, submission strategy, adjournments, alerts, technical glitches, and portal mechanics.
- Legal Conundrums in Practice: Issues involving insufficient response time, cross-examination, relied-upon material, SCN deadlines, jurisdiction, DIN, and other procedural concerns.
- Drafting Documents in the Practitioner's Toolkit: Grounds of appeal, statement of facts, condonation petitions, affidavits, additional evidence applications, stay applications, and written submissions.
- Doctrines, Citation Craft and Case-Law Research: Guidance on statutory interpretation, case-law research, reading orders, citation discipline, and avoiding unreliable AI-generated citations.
- Other Faceless and e-Proceedings: e-Verification, Faceless Inquiry or Valuation, Faceless Jurisdiction, e-Dispute Resolution, e-Assessment of Income Escaping Assessment, e-Advance Rulings, and e-Rectification.
- Alternative Remedies Outside the Faceless Track: E-Nivaran, writ jurisdiction, RTI, CPGRAMS, repetitive-appeal protection, immunity provisions, Dispute Resolution Committee, and High-Pitched Assessment Committee.
- Continuing Role of Jurisdictional Authorities: Residual powers of the JAO, Commissioner's supervisory jurisdiction, PCIT revision jurisdiction, and escalation pathways.
- Natural Justice as Connective Thread: Speaking-order requirement, opportunity to be heard, cross-examination, access to relied-upon documents, and video-conference rights.
Book Structure
- Block I – The Faceless Regime Itself (Chapters 1 to 4): History and journey, faceless assessments, faceless appeals, and faceless penalty.
- Block II – Drafting, Allied Proceedings and Alternative Remedies (Chapters 5 to 8): Drafting curriculum, worked case scenarios, allied e-proceedings, and alternative remedies.
- Appendices: Five appendices reproducing the underlying source material in full.
The book combines black-letter exposition with internal CBDT SOPs, an original survey of 25 senior tax practitioners, and fifteen worked case scenarios with full specimen submissions, with deliberate emphasis on the craft of written advocacy in faceless proceedings.
30% OFF
