Faceless assessment, written as your procedure rather than their org chart

What faceless actually changes for you

The organisational machinery — a national centre allocating cases electronically to anonymous units that assess, verify, advise and review — is what every other page on this subject describes. It is also the part you cannot influence and do not need to understand in detail.

What matters is the three things it changes about your position. There is nobody to go and see, so nothing gets resolved by explanation in a room. Everything is written, so the quality of the written submission is the whole of your case. And because the unit reading your reply knows nothing about you beyond the file, context that would be obvious in person has to be supplied explicitly.

That cuts both ways. The old system's informality helped people who were good at it and hurt people who were not. A written system is fairer to someone with a good case and worse for someone relying on being believed.

The three things you can actually do

None of these happens automatically. A system that never telephones you also never reminds you, and the commonest failure in a faceless assessment is not a bad argument but a date that passed while somebody was gathering documents they had not asked for an extension to gather.

1. 1Respond. Under Pending Actions, then e-Proceedings, with a written submission and attachments. This is the case — answer the specific question asked, attach the evidence rather than describing it, and explain the commercial reality in plain words.
2. 2Ask for more time. An adjournment is requested through the same screen, and it must be requested before the date given rather than after it passes. One is commonly granted and a second less commonly. Where a third party has to confirm something, start that on the day the notice arrives, because confirmations take longer than the period allowed.
3. 3Ask for a hearing by video. Request it through the portal, and ask early rather than waiting until a show-cause has been issued. It is the one opportunity to be heard rather than read, and it is worth using where an issue turns on something hard to convey on paper.

The show-cause, and why it is the whole case

Before any variation prejudicial to you is made, a show-cause should be issued setting out what is proposed and why, so that you can object to it. In practice this arrives with a draft of the proposed assessment.

This is the last stage at which the assessment can be shaped rather than appealed. After the order, your options cost a fee and years. At the show-cause stage the same argument costs a written reply, and the unit deciding has not yet committed to anything.

So it should be answered fully rather than briefly, on each proposed variation separately, with the documents. And if the period given is short — seven days is common — that is precisely when to request an adjournment rather than to file something thin.

What makes a written reply work

The single commonest failure is a thin reply: two lines saying the transaction was genuine, with nothing attached. In a system where nobody can ask a supplementary question, that is the same as saying nothing.

• Answer the question that was asked. A reply restating the return without engaging with the specific issue reads as no reply at all.
• Attach, do not describe. Bank statements, invoices, agreements, confirmations, ledger extracts — the file is the case and nobody will ask for what is missing.
• Supply the context. A faceless unit sees a number without a story, and the story is usually the answer.
• Stay inside the issues raised. Where the scrutiny is limited to named issues, volunteering material about other years or transactions invites the enquiry to widen.
• Deal with the reasoning, not the conclusion. If the notice explains why something looks wrong, address that reasoning directly.
• Number things. Submissions that track the questions in order are easier to accept than prose that requires the reader to map it themselves.

What is not done faceless

The scheme is not universal. Certain categories have been kept outside it — broadly, cases involving serious fraud, major tax evasion, sensitive and search matters, international taxation and black money have been excluded from the faceless route at various points since the scheme began.

The practical significance is limited for most readers, but worth knowing for two reasons. If your assessment is being conducted with an identified officer you can contact, that is not necessarily irregular. And if it is being conducted faceless, the procedural protections described on this page apply and are worth insisting on.

After the order

The assessment order arrives with a demand notice if anything has been added, and from that point the ordinary machinery applies — thirty days to pay or respond, thirty days to appeal, and a separate application if you want the demand stayed.

Where the complaint is about the process rather than the conclusion, there are two routes and they are not alternatives to be chosen casually. An appeal to the Commissioner (Appeals) reconsiders everything, including whether the assessment should have been made as it was. A writ petition to the High Court challenges the legality of the process itself, and is the route where a fundamental opportunity was denied — an addition never put to you, a reply on the file that was never considered, an order passed before the period given had expired.

A writ is not a general alternative to an appeal and courts will usually say so where an effective appellate remedy exists. It is for the cases where what went wrong is the process rather than the answer, and those cases are made out on the record you kept.

Worked examples