Faceless Appeal Scheme: How Income Tax Appeals Work Now

If you have filed a first appeal against an income tax order recently, you are almost certainly navigating it through the Faceless Appeal Scheme rather than a traditional in-person hearing before a named Commissioner. This guide explains how the mechanism actually works, who is excluded from it, and what a response under this scheme should look like. For the deadlines and forms that get you into this system in the first place, see our companion guide on the full appeal process from CIT(Appeals) to ITAT.

The Structure Behind a Faceless Appeal

The scheme runs through a small set of coordinating bodies rather than a single officer sitting across the table from you. The National Faceless Appeal Centre (NFAC) acts as the central hub: it receives the appeal, communicates with you, and allocates the case. The actual work of examining the appeal and drafting the order is done by an Appeal Unit in a Regional Faceless Appeal Centre, assigned through an automated, randomised allocation algorithm rather than manual assignment.

This structure is deliberate: the taxpayer generally does not know, and does not need to know, which specific officer within the assigned unit is reviewing the case. The intent is to remove the personal-relationship element from the appellate process entirely, reducing scope for both bias and undue informal influence in either direction.

What Is Excluded From the Faceless Mechanism

Not every appeal goes through this route. Categories carved out and kept on the conventional, non-faceless track include appeals involving serious fraud, major tax evasion, sensitive matters, and cases arising from search and seizure operations, along with international taxation and black money cases. These categories often require coordination, specialised expertise, or handling that the standard faceless workflow is not designed for, so they continue through the traditional appellate route with an identified officer.

If your matter falls into one of these excluded categories, do not assume it will proceed on the faceless system's typical timelines or communication pattern; confirm with your CA which track your specific appeal is actually following.

How the Process Actually Runs

Once your appeal is filed and allocated, communication happens almost entirely through the income tax e-filing portal: notices asking for clarification or additional evidence, your written submissions in response, and eventually the appellate order itself, all logged against the appeal reference with real-time alerts on filing and disposal. There is no walk-in hearing room in the traditional sense.

That does not mean a hearing is never available. In appropriate cases, typically where the matter is factually or legally complex enough that a purely written exchange risks losing nuance, a request for a hearing can be made and is conducted by video conference rather than in person. The default posture of the system, however, is written submission, and most appeals proceed and conclude without ever reaching a live hearing.

When the Appeal Unit finalises its view, the order is issued electronically with a digital signature and communicated to both you and the assessing officer's side simultaneously, closing the loop on that stage of the dispute.

What This Means for How You Respond

The practical shift for taxpayers is that the quality of your written submission now carries more weight than it might have in a traditional hearing, where a point could sometimes be clarified verbally on the spot. A submission under the Faceless Appeal Scheme should:

• Directly address each specific finding or ground raised in the order under appeal, not just restate your original position.
• Attach complete, clearly labelled supporting documents the first time, rather than assuming a follow-up round to add missing evidence.
• Be internally consistent with what was already submitted at the assessment stage; contradictions between your assessment-stage and appeal-stage submissions are an easy target for the Appeal Unit to flag.
• Explicitly request a hearing if the matter genuinely needs one, rather than assuming it will be offered automatically.

This is broadly the same discipline that applies when responding to a faceless scrutiny notice at the assessment stage: complete, well-organised, first-submission-correct responses move faster and more favourably through a faceless system than partial responses that anticipate a chance to fill gaps later.

Faceless Appeal vs Faceless Assessment

It is worth keeping the two faceless mechanisms distinct. The Faceless Assessment Scheme governs how your original scrutiny assessment under Section 143(3) is conducted, before any dispute exists. The Faceless Appeal Scheme covers what happens after you disagree with that (or another) order and file a first appeal. Both apply the same underlying philosophy of randomised allocation and portal-based communication, but they sit at different stages of the same broader dispute lifecycle, and the exclusion criteria (fraud, search cases, international tax) are similar but decided independently at each stage.

Whether you are still deciding whether an order is worth appealing or you already have a faceless appeal notice in hand and are unsure how to respond, involving a CA who has handled faceless proceedings before materially improves how the written record reads to the Appeal Unit. Our tax advisory services include drafting and managing faceless appeal submissions end to end.