ORDER

PER RAKESH MISHRA, ACCOUNTANT MEMBER:

This appeal filed by the assessee is against the order of the Commissioner of Income Tax (Appeals)-NFAC, Delhi [hereinafter referred to as Ld. 'CIT(A)'] passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2013-14 dated 11.12.2025.

1.1 The Registry has informed that the appeal is barred by limitation by 14 days. The assessee has filed a petition along with an affidavit for condonation of delay explaining the reasons that the assessee is a small taxpayer from a village with limited financial and tax literacy, who remained unaware of the previous appeal rejection order dated 11.12.2025 and could not travel to check the status until March 2026 due to continuous medical supervision since the onset of COVID-19 pandemic. After perusing the same, we are satisfied that the assessee had a reasonable and sufficient cause and was prevented from filing the instant appeal within the statutory time limit. We, therefore, condone the delay and admit the appeal for adjudication.

2. The assessee is in appeal before the Tribunal raising the following grounds of appeal which are argumentative:

"1. That having regard to the facts and circumstances of the case, the issue of notice under Section 142(1) of the Income Tax Act, 1961 by the National Faceless Assessment Centre is without any jurisdiction, as the provisions of Section 151A were notified from 29.03.2022 vide Notification No. 18/2022/F.No.370142/16/2022-TPL(Part1)

1.1. It is humbly submitted that the proceedings under Section 147, more particularly notice dated 24.09.2021, 26.11.2021 and 17.12.2021 issued under Section 142(1) of the Income Tax Act, 1961 by National Faceless Assessment Centre are without any jurisdiction.

1.2. The Legislature had vide Taxation and Other Law (realisation and amendment of certain provisions) Act, 2020 introduced Section 151A of the Income Tax Act, 1961 with effect from 01.11.2020, which had provided for making a scheme for faceless assessment under the Income Tax Act, and reads as under.

"151A: (1) The Central Government may make a scheme, by notification in the Official Gazette, for the purposes of assessment, reassessment or re-computation under section 147 or issuance of notice under section 148 or conducting of enquiries or issuance of show-cause notice or passing of order under section 1484 or sanction for issue of such notice under section 151, so as to impart greater efficiency, transparency and accountability by

(a) eliminating the interface between the income-tax authority and the assessee or any other person to the extent technologically feasible;

(b) optimising utilisation of the resources through economies of scale and functional specialisation;

(c) introducing a team-based assessment, reassessment, re-computation or issuance or sanction of notice with dynamic jurisdiction.

(2) The Central Government may, for the purpose of giving effect to the scheme made under sub-section (1), by notification in the Official Gazette, direct that any of the provisions of this Act shall not apply or shall apply with such exceptions, modifications and adaptations as may be specified in the notification:

Provided that no direction shall be issued after the 31st day of March, 2022.

(3) Every notification issued under sub-section (1) and sub-section (2) shall, as soon as may be after the notification is issued, be laid before each House of Parliament.

1.3. It is further submitted that though the provisions were introduced into the Income Tax Act with effect from 01.11.2020, the scheme for faceless assessment were notified only on 29.03.2022 vide Notification No. 18/2022/F, No. 370142/16/2022-TPL(Part).

1.4. As the scheme for faceless assessment were brought into effect only from 29.03.2022, it is undisputable that the National Faceless Assessment Centre was granted jurisdiction to conduct proceedings under Section 147 of the Income Tax Act only from 29.03.2022 and not before such date.

1.5.