Business Enquiries +91-9819 000 227 / +91-9819 000 511 / +91-9819 000 147 / +91-9765 000 966
A Section 143(2) notice under the Income-tax Act, 1961 is the formal statutory intimation served by the Assessing Officer (or more commonly today, by the National Faceless Assessment Centre (NaFAC) under Section 144B) that a return filed by the taxpayer has been selected for scrutiny assessment. Unlike the automated Section 143(1) summary processing — which is essentially a CPC-driven arithmetical verification — a Section 143(2) scrutiny is a deep, merit-based examination of the return under Section 143(3) of the Act, potentially spanning every income head, every deduction, every disclosure, and every supporting document in the taxpayer's books. A scrutiny notice is therefore one of the most consequential communications a taxpayer can receive from the tax department — it marks the beginning of a 12-month assessment cycle (under Section 153) that can culminate in a Section 143(3) order with additions to income, interest, Section 270A mis-reporting penalty, and demand under Section 156 — and, in adverse cases, Section 270A penalty notices at 50% (under-reporting) or 200% (mis-reporting) of the tax on the additions.
The power to issue a Section 143(2) notice is circumscribed by statute. Under the proviso to Section 143(2), the notice must be served on the assessee within 3 months from the end of the financial year in which the return is filed — this is a strict time limit, and a notice served beyond this window is void and confers no jurisdiction to assess. Selection for scrutiny happens through multiple channels — Computer Assisted Scrutiny Selection (CASS) based on risk parameters and data-matching against Form 26AS / AIS / TIS / SFT under Section 285BA, Limited Scrutiny cases confined to specified issues, Complete Scrutiny covering the whole return, Compulsory / Manual Scrutiny (for search, survey, reopened cases, exemption-denied trusts, and other specified categories), and Transfer Pricing references to the TPO under Section 92CA extending the assessment time limit. Whatever the category, the procedure that follows is substantially the same — a detailed Section 142(1) questionnaire, responses uploaded via the e-filing portal's e-Proceedings module, video-conference hearings where permitted (typically when material adverse variation is proposed), and a Section 143(3) final order after a Section 144B show-cause on the draft order.
Our Section 143(2) Notice Response Services cover the full scrutiny defence cycle — from decoding the notice and identifying whether it is Limited, Complete, or Compulsory scrutiny (each has a different defence playbook), testing service-date validity against the Section 143(2) proviso time limit (often a game-changing jurisdictional defence), building a point-wise reconciliation of the ITR with Form 26AS / AIS / TIS / Form 16 / 16A / books / GST data, drafting technical and legal responses to each item in the Section 142(1) questionnaire, compiling contemporaneous documentary evidence and case-law support, filing through the faceless e-Proceedings module within every deadline, requesting and attending video-conference hearings where material variations are proposed, responding to Section 144B show-cause notices on draft orders, defending penalty proceedings under Sections 270A and 271(1)(b), filing first appeals before CIT(A) under Section 246A and second appeals before ITAT under Section 253 where adverse orders are passed, securing stay of demand under Section 220(6) (20% pre-deposit norm) and Section 254(2A), and taking the matter to the jurisdictional High Court under Section 260A and the Supreme Court under Section 261 where needed — so the taxpayer walks through scrutiny with minimum additions, minimum interest, minimum penalty, and a clean record for future years.
CASS-selected return with scrutiny confined to specified issues identified at selection stage.
Full examination of the return — every income head, deduction, disclosure, and transaction.
Non-CASS compulsory categories — post-search, post-survey, trust exemption withdrawal, specified risk.
Cases with international transactions / SDT referred to TPO — extended time limit and DRP route.
Section 143(2) notices issued in ongoing Section 148 reassessment proceedings for escaped income.
Specific scrutiny of trusts under Sections 11 / 12 / 10(23C) — 85% application, 115BBC, 115TD risks.
Notice must be served within 3 months from end of FY of filing — strict jurisdictional test.
Service by email, registered post, portal, or affixture — defective service voids the notice.
After 143(2), AO / NaFAC issues a Section 142(1) questionnaire listing issues and calling for information.
Scrutiny via NaFAC with Assessment / Verification / Technical / Review Units; e-Proceedings only.
VC hearing granted at NaFAC discretion where materially adverse variation is proposed.
Before finalising, NaFAC issues SCN on proposed variation — last chance to stop adverse order.
Section 143(3) order must be passed within 12 months from end of AY; 24 months with TPO reference.
Adverse 143(3) order typically initiates Sec 270A penalty at 50% (under) / 200% (mis-reporting).
Read and classify notice, test jurisdiction, map scope, and draft a defence roadmap.
Point-wise reply with case-law and documentary evidence uploaded on e-Proceedings module.
Draft order review, final order, stay, rectification, CIT(A) first appeal and ITAT second appeal.
Issue-wise reply to CASS limited scrutiny — preventing scope expansion and closing cleanly.
End-to-end defence of complete scrutiny with full questionnaire handling and VC representation.
Defence of post-search / post-survey / trust / reopened 143(2) notices with documentary build-up.
Section 92CA TPO response, DRP objection route, and TP order defence with documentation discipline.
Full faceless e-Proceedings representation, VC hearing, and Sec 144B show-cause reply.
Penalty defence under Sec 274 — immunity u/s 270AA and mis-reporting vs under-reporting defence.
Section 220(6) stay with 20% pre-deposit norm, coordination with AO, and bank-attachment defence.
First appeal before CIT(A) and second appeal before ITAT with stay and rectification strategy.
Return selected for scrutiny within 3 months of filing — strict timeline has begun.
Detailed NaFAC / AO questionnaire requiring point-wise documented response.
AIS reports dividends / interest / CG / property sale not reflected in ITR — scrutiny risk is high.
GSTR-1 / 3B turnover not reconciling with ITR — common data-matching trigger.
SFT-reported property, equity, cash, or forex transactions above threshold under Section 285BA.
Section 143(2) in ongoing search assessment under Section 153A / 153C with heavy exposure.
NaFAC has issued Sec 144B show-cause on proposed adverse variation — urgent reply required.
Notice served beyond 3-month window — strong jurisdictional defence; void-ab-initio argument.
Classify notice, check service validity, and scope-map issues from 142(1) and related data.
AIS / 26AS / books / ITR tie-out and risk-rated defence roadmap with evidence mapping.
Point-wise reply with evidence and precedents uploaded on e-Proceedings within deadline.
VC hearings and Sec 144B show-cause replies on proposed adverse variations.
143(3) order review, Sec 220(6) stay, CIT(A) / ITAT appeals, and penalty defence.
Partner with our CAs and advocates for end-to-end Section 143(2) Notice Response Services — point-wise replies, VC hearings, Sec 144B defence, penalty and appeal support — all under one roof.
Talk to a Scrutiny Expert