20 February 2026
Under the faceless appeal regime, oral hearings before the CIT(Appeals)/NFAC are the exception rather than the rule. In most matters, the entire case is made — and decided — on the strength of the written submission. That shifts a significant amount of what used to happen in argument into the drafting stage itself.
A submission that a faceless officer can act on efficiently tends to follow a consistent structure: a short statement of facts, ground-by-ground legal submissions with each ground addressed independently, and supporting case law cited precisely rather than in bulk. Submissions that bury the strongest point among weaker ones risk the strongest point being missed entirely.
Because there is no back-and-forth in real time, an effective submission also anticipates the department's likely response and addresses it pre-emptively, rather than waiting for a rejoinder opportunity that may not meaningfully arise.
A request for video-conferencing hearing can be made, and is granted in specified circumstances. Where the matter turns on a nuanced factual explanation that is difficult to convey fully in writing, requesting a hearing — and being ready to justify why it is necessary — is often worth the effort.