HC declined to allow voluminous documents physically in Faceless Assessment

High Court declined to allow production of physical documents by in Faceless Assessment simply because they were voluminous

In a recent judgment, Hon’ble High Court has declined Petitioner appeal to allow him production of documents by physical mode in Faceless Assessment on the ground that they were voluminous.

ABCAUS Case Law Citation:
5059 (2026) (02) abcaus.in HC

Faceless Assessment Scheme was introduced in 2019 to facilitate faceless assessment of income tax returns through completely electronic communication between tax officials and tax payers. Under Faceless Assessment, income tax scrutiny assessments are conducted without physical interaction between the taxpayer and the assessing officer. Everything happens electronically through the e-filing portal.

Section 144B of the Income Tax Act, 1961 (the Act) deals with Faceless Assessment and provides that modalities of a Faceless Assessment by National Faceless Assessment Centre (NFAC) through Assessment Unit. It is notable that all the documents required by the NFAC are to be uploaded digitally by the assessee.

In the instant case, the grievances highlighted by the assessee (writ petitioner) were pertaining to the manner in which the assessment proceedings under Section 144B of the Income Tax Act were proceeded with.

It was submitted that the petitioner was required to furnish the details regarding the nature of the business activities carried out during the financial year. He was also required to furnish detailed computation of total income along with Balance Sheet and Profit & Loss Account. According to the petitioner, the documents sought to be produced were voluminous and therefore it may not be possible for the petitioner to upload the same in the e-filing web portal.

The Petitioner prayed for order directing the Assessment Unit to permit the petitioner to produce the book of accounts/ other documents manually before any designated officer of the Department.

The Revenue opposed the Petition and stated that Section 144B(5) contemplates that all the documents that should be produced during the course of proceedings under Section 144B can only be through electronic mode and physical copies cannot be produced. It was stated that granting permission to produce physical documents is not feasible, going by the Faceless Assessment Scheme contemplated under the said provision.

The Hon’ble High Court observed that as per the faceless assessment scheme the records are to be perused and the evidence to be adduced only through electronic mode and it cannot be done through physical mode. It was evident that the petitioner was in possession of the documents and therefore nothing prevented the petitioner from the converting of the physical documents as electronic documents and upload the same in the web portal for completing the assessment proceedings.

However, as the petitioner required some time to upload the said documents, The Single Judge permitted additional time for uploading the documents.

Not satisfied with the order of the Single Judge, the Petitioner filed a Writ Appeal before a Division Bench to allow it to produce the physical documents. In alternative, the assessee prayed for extension of the time frame allowed for uploading the documents online.

However, the Division Bench held that going by the Statutory Scheme, particularly the provisions of Section 144B(5) of the ‘Act’, documents can only be produced through the online mode; and therefore, no exception can be given to the appellant, whatever be the reason. The Bench held that when the applicable Statute provides for a particular course, it has to be done in the same manner, and no other.

The Bench further extended the time frame for the appellant to upload his documents, as per Section 144B(5) of the Act.

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