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(c) "automated allocation system" means an algorithm for randomised allocation of cases, by using suitable technological tools, including artificial intelligence and machine learning, with a view to optimise the use of resources;

(d) "automated examination tool" means an algorithm for standardised examination of draft orders, by using suitable technological tools, including artificial intelligence and machine learning, with a view to reduce the scope of discretion;

6.9. Hon'ble Prime Minister, on 13th August, 2020, introduced a revamped scheme for tax assessments. Accordingly, the e- Assessment scheme was renamed as the faceless assessment scheme. Notifications were also issued i.e., No. 2745(E) (Notification No. 60/2020 (F No. 370149/154/2019-TPL)] dated 13.08.2020) and No. 2746(E) (Notification No. 61/2020 (F No. 370149/154/2019-TPL)] dated 13 August 2020) with the details of the faceless scheme. With this scheme, the Government introduced 'Faceless Appeal' and the 'Taxpayers' Charter'. 6.10. Under the Faceless Assessment Scheme, all cases for tax assessments, other than those allotted to central and international tax charges, are selected by an automated allocation system through the use of artificial intelligence (AI) and machine learning tools. The same suggests a 360-degree profiling of taxpayers, and aims to enable more focused and meaningful assessments than in the past. This system, comprises of a team-based assessment mechanism having multiple layers of units formed by the CBDT. The same has also been extended to CIT (A) proceedings. This has made appeal proceedings being governed in a similar manner as faceless assessments. It involves the concept of dynamic [2025:RJ-JD:4984-DB] (58 of 67) [CW-11787/2024] jurisdictions to increase the objectivity of appeal orders and instil transparency and efficiency in such proceedings. 6.11. The Taxpayers' Charter seeks to strengthen the relationship between the Income-tax Department and the taxpayer in the new regime. Its objective is to inculcate a trust-based relationship between the two, and enhance the department's service delivery system's efficiency.

19. This Court is conscious of the fact that any reform or change for betterment is always resisted by the persons in control, particularly those who do not visualize the pragmatic and progressive paths which require vision and wisdom. The legislature in its own vision and wisdom, for enhancing the efficiency of the taxation system by making it more transparent and impartial, decided to have infused technology in the shape of an algorithm for randomised allocations of cases, by using suitable technological tools, including artificial intelligence and machine learning, with a view to optimise the use of resources. The common tendency to cling to control and old methods has to be dealt with firmly and ways & means including loopholes to fall back upon the old regime of control is an imminent danger which has to be thwarted off. The legislative intention, legislative vision and legislative wisdom has to be given full meaning in terms of technology and progressiveness, and thus, once an effective and strong step has been taken towards faceless regime, then maintaining the strings of local control to the prejudice of a common man would not only undermine the legislative wisdom but the gains in terms of such a progressive and pragmatic step would stand to reduce. Once the gear of progress has been applied in a democratic set up, the same has to be strongly supported and sustained. The CBDT Circular read with Section 151A of the Act of 1961 has to be given full meaning and any ways & means to defeat the technology or to manually try to control the same would go against the legislative purpose.