Sulaiman Jamal Vs National Faceless Assessment Centre (Karnataka High Court)
Faceless Assessment Invalidated for Breach of SOP: SCN Granting Less Than 7 Days’ Time Vitiates Entire Proceedings
The Karnataka High Court, in Sulaiman Jamal vs. National Faceless Assessment Centre & Ors. (W.P. No. 19344 of 2021, order dated 01-Dec-2025), quashed the faceless assessment order u/s 143(3) r/w s.144B, along with the computation sheet, demand notice u/s 156, and penalty notices u/s 274 r/w ss.271AAC(1) & 270A for AY 2018-19, on account of violation of the mandatory Standard Operating Procedure (SOP).
The Court found that the show-cause notice dated 21-06-2021, accompanied by a draft assessment order, allowed the Assessee less than seven days to respond, which was contrary to the prescribed SOP and principles of natural justice. Following the binding coordinate-bench ruling in P.A. Educational Trust vs. Assessment Unit (order dated 29-04-2025), the Court held that such curtailed opportunity renders the entire assessment proceedings unsustainable.
Accordingly, all impugned orders and notices were set aside, and the matter was remanded to the Assessing Officer to recommence proceedings from the stage of filing reply to the show-cause notice, with all contentions kept open and liberty reserved to the Assessee to raise every plea available in law.
FULL TEXT OF THE JUDGMENT/ORDER OF KARNATAKA HIGH COURT
