Income Tax Scrutiny Notice — Section 143(2) Reply
Last updated: 14 Oct 2026
Quick Answer: A Section 143(2) scrutiny notice informs taxpayers that the Income Tax Department is performing a detailed examination of their return. Recipients must provide a systematic, document-backed response to Assessing Officer queries. Common triggers include large cash deposits, high-value property purchases, or mismatches in salary and capital gains reporting.
Expert reply to Income Tax scrutiny notice under Section 143(2). CA representation before AO, document preparation, assessment strategy, and faceless assessment response.
Income Tax Scrutiny — What It Means
An income tax scrutiny notice under Section 143(2) is a formal intimation that the Income Tax Department is examining your return in detail, beyond the routine processing. It does not mean fraud has been detected — most scrutiny cases are risk-based computer selections. However, it does require a systematic, document-backed response to every query raised by the Assessing Officer (AO) or the National Faceless Assessment Centre (NFAC).
Scrutiny Notice Types and Scope
| Notice Type | Section | Purpose | Scope |
|---|---|---|---|
| Limited Scrutiny | 143(2) | One or two specific issues identified by CASS | Restricted to specified issues only — AO cannot expand scope |
| Complete Scrutiny | 143(2) | Full examination of return | All items in return open for scrutiny |
| Manual Selection | 143(2) | High-value or risk-flagged cases | Usually complete scrutiny |
| E-Proceedings | 143(2) + Faceless Scheme | Faceless assessment via portal | Complete or limited — specified in notice |
Common Scrutiny Triggers
Financial Triggers
- Cash deposits in banks — especially large deposits in FY 2016-17 (demonetisation period); CBDT still processing those cases
- High-value property purchases — SFT-006 reports from registrars trigger scrutiny
- Foreign remittances — Form 15CA/CB filed for outward remittances are matched against declared income
- Large capital gains — especially from unlisted shares, property, or mutual funds
- Salary mismatch — declared salary in return vs TDS certificate (Form 16) mismatch
- High deductions — Chapter VI-A deductions disproportionate to income
- Turnover mismatch — GST turnover vs declared income in return
Transaction-Based Triggers
- Share transactions reported to SEBI vs capital gains declared
- Startup investors — Section 56(2)(viib) premium received
- Cash sales in business — large cash sales flagged by bank account analysis
- Professional services with high TDS (lawyers, doctors, architects) — TDS income vs return mismatch
The Scrutiny Process — Timeline
| Step | Timeline | Action Required |
|---|---|---|
| Section 143(2) notice issued | Within 3 months of FY end (return filing FY) | Acknowledge notice on IT portal |
| Section 142(1) questionnaire | Typically within 30–60 days of 143(2) | Respond with documents within specified time |
| Additional queries | Multiple rounds — 30 days each | Detailed written response with evidence |
| Draft Assessment Order (DAR) | Before final order — mandatory under faceless scheme | File objections within 30 days |
| Final Assessment Order (143(3)) | Within 9 months from end of AY | Comply or appeal within 30 days |
How to Respond to a Scrutiny Questionnaire
Documents Typically Required
- Bank statements for all accounts (savings, current, FD) for the relevant FY
- Audited financial statements (if applicable) with schedules
- Form 26AS / AIS / TIS reconciliation with return
- Property purchase/sale documents with valuation reports
- Investment proofs for Chapter VI-A deductions
- Books of accounts — cash book, ledger, journal
- Contract documents for large transactions
- Details of cash credits (Section 68) — identity, creditworthiness, genuineness of creditors
Response Strategy
- Address every query — silence on any query point is an implicit admission
- Provide documentary evidence — every explanation needs a supporting document
- Cite applicable sections and case law — for contentious issues (e.g., Section 68 additions)
- Establish identity, creditworthiness, and genuineness for cash credits (the three-prong test)
- Challenge scope expansion — in limited scrutiny, the AO cannot examine issues beyond those specified in the 143(2) notice
- File written submissions before personal hearing (in physical assessment cases)
Challenging Proposed Additions
Section 68 — Unexplained Cash Credits
If the AO proposes to add unexplained cash credits to income, you must establish: (1) Identity of the creditor (PAN, address), (2) Creditworthiness (creditor's income/financial position to lend), (3) Genuineness of the transaction (banking channel, contract, purpose). Failure on any prong results in addition. Counter: cite Supreme Court ruling in CIT v. Orissa Corporation — onus shifts to department if you provide prima facie evidence.
Section 69 — Unexplained Investments
For investments not fully explained from declared income sources. Provide: source of funds (inheritance, gifts, savings, prior year accumulated income), documentation, and return of the source's income.
Section 40A(3) — Cash Payment Disallowance
Payments above ₹10,000 cash to a person in a day are disallowed under Section 40A(3). Exceptions apply for Rule 6DD categories (payments to banks, agricultural payments, remote areas). Cite the exceptions applicable to your case.
Our Scrutiny Assessment Service
- Notice analysis — scope, time limits, grounds raised
- Document compilation and indexing
- Written response drafting with case law support
- Form 26AS/AIS reconciliation statement
- Representation before NFAC (faceless) or AO (physical)
- Objections to Draft Assessment Report
- Appeal filing if final order makes additions
Received a scrutiny notice? Respond within the deadline — delays cost you the right to be heard.
Get Scrutiny Notice Help Call +91-9962 260 333Frequently Asked Questions
What is a Section 143(2) notice?
Section 143(2) of the Income Tax Act is a scrutiny notice served by the Assessing Officer (AO) to the taxpayer within 3 months from the end of the financial year in which the return was filed. It initiates a detailed assessment of the return beyond the summary processing done under Section 143(1).
What triggers a scrutiny notice?
Cases are selected for scrutiny through: (1) CASS (Computer Aided Scrutiny Selection) based on risk parameters, (2) Manual selection by CCIT/DG for specific cases (high-value transactions, mismatches), (3) Survey/search cases, (4) Information received from third parties. Common triggers: large cash deposits, foreign remittances, high deductions, significant difference between declared income and TDS/26AS data.
What is the difference between scrutiny and assessment?
Scrutiny under Section 143(2) leads to regular assessment under Section 143(3). The AO issues questionnaires, the taxpayer provides documents and explanations, and the AO then passes an assessment order either accepting the return or making additions/disallowances.
What is the time limit to complete scrutiny assessment?
Assessment under Section 143(3) must be completed within 9 months from the end of the Assessment Year. For AY 2024-25 (FY 2023-24 returns), the assessment must be completed by December 31, 2025.
What happens in faceless assessment?
Under the Faceless Assessment Scheme, the scrutiny is conducted by the National Faceless Assessment Centre (NaFAC). There is no physical interface between the taxpayer and AO. All communication is through the Income Tax portal. The taxpayer submits responses electronically.
Can I appear personally before the AO?
Under faceless assessment, personal appearance is generally not allowed (the scheme is designed to be faceless). However, in cases where the NFAC decides to revert to physical assessment (complex cases), the taxpayer can appear. Under old-style physical assessments, the taxpayer or CA representative can appear.
What are typical additions in scrutiny assessment?
Common additions: (1) Cash credits under Section 68 (unexplained cash/loans), (2) Unexplained investments under Section 69, (3) Disallowance under Section 40A(3) (cash payments exceeding ₹10,000), (4) MSME payment disallowance under Section 43B(h), (5) Unexplained expenditure under Section 69C, (6) Transfer Pricing adjustments.
What does this income-tax notice require, and what should I submit?
First identify the notice: an intimation of adjustments after processing (section 143(1)), a scrutiny notice (section 143(2)) with questions under section 142(1), a reassessment notice (sections 148A and 148), or a demand or penalty notice (the Income-tax Act, 1961 for tax years up to 2025-26; the corresponding provisions of the Income-tax Act, 2025 from tax year 2026-27). Check the assessment year, the Document Identification Number, the date of service and the deadline. Then gather what is asked for, reconcile the department’s figures with your return and AIS, and reply on the e-filing portal, asking for an adjournment or a hearing where needed. Ignoring a notice can lead to a best-judgement assessment and penalties. We review the notice confidentially and prepare the reply and supporting schedule.
Faceless Scrutiny — Specific Best Practices
Under the National Faceless Assessment Centre (NFAC) scheme, the scrutiny response must be comprehensive and self-contained because there is no opportunity for informal clarification. Key NaFAC-specific best practices:
- Every document must be uploaded as a named, indexed PDF — not raw scanned images that are illegible. File naming convention: "Q1_Salary_Income_Form16_AY2024-25.pdf"
- Create a cover note that lists every query number and the corresponding document/page reference that addresses it
- For large document sets: upload a single PDF index document first, then numbered documents corresponding to the index
- The NFAC portal has file size limits — use PDF compression and split large documents into parts
- Always check the portal acknowledgement after uploading — the upload must show "Submitted" status, not just "Saved"
AIS vs 26AS — Which Controls for Scrutiny?
From AY 2021-22, the Annual Information Statement (AIS) on the IT portal replaces Form 26AS as the primary data source for the department. AIS contains much richer data than 26AS: it includes buying/selling of securities, real estate transactions, foreign remittances, dividends, interest, and more. Before responding to any scrutiny notice, download and review your AIS for the relevant year — the AO's queries are likely based on AIS data that doesn't match your return. Common AIS vs return discrepancies to check: securities transactions not declared as capital gains, rental income from AIS not declared, foreign remittances not explained.
Limited Scrutiny — Scope Cannot Be Expanded
A CASS-selected limited scrutiny is restricted to one or two specific issues identified in the Section 143(2) notice itself. The AO cannot convert it to a complete scrutiny or raise issues beyond those specified, without obtaining approval from the PCIT. If the AO is raising queries about items not specified in the 143(2) notice, clearly raise this objection in your response: "The present scrutiny is a limited scrutiny under CASS for [specified issue]. The query at serial number X relates to [different issue] which is not within the scope of this limited scrutiny. This expansion of scope is impermissible without PCIT approval under the CBDT guidelines on CASS selection."
Transfer Pricing in Scrutiny — Domestic and International
If the taxpayer is a company with related party transactions — whether domestic (Section 40A(2) transactions with specified persons) or international (Section 92 transactions with associated enterprises) — these are priority scrutiny areas. The Assessment Unit frequently makes additions under Section 40A(2) for payments to related parties at non-arm's-length prices (e.g., rent paid to promoter's family's property at above-market rates, or salaries paid to promoter family members disproportionate to role). Maintain transfer pricing documentation for all related party transactions above materiality thresholds, even domestic ones.
Section 50C Trap in Property Scrutiny
When an immovable property is sold at a price below the Stamp Duty Value (SDV / circle rate), Section 50C deems the SDV as the sale consideration for capital gains computation in the seller's hands. The AO will compute your capital gains using the SDV even if you actually received less. To challenge this: (a) if the SDV was fixed more than 6 months before the date of agreement, use the SDV at the date of agreement (not registration) — Finance Act 2016 provision; (b) if you believe the SDV itself is wrong, apply to the AO to refer to the District Valuation Officer (DVO) for an independent valuation — if DVO value is lower than SDV, DVO value is used for Section 50C computation.
Related Services
- Income Tax Appeal — CIT(A) & ITAT
- Section 148 Reassessment Notice
- Faceless Assessment India
- GST Notice Reply
- Forensic Accounting
Which laws govern this service? — Income tax
The statutory provisions this service is delivered under, linked to the official text:
- Income-tax Act, 2025 (in force from 1 April 2026; replaces the 1961 Act for tax year 2026-27 onward) and Income-tax Rules, 2026
- Income-tax Act, 1961 — s.246A (appealable orders), s.250 (procedure), s.253 (appeal to ITAT)
- Income-tax Act, 1961 — s.148 and s.148A (reassessment), s.263 (revision), s.270A (penalty)
- Faceless Appeal Scheme, 2021 and Faceless Assessment (s.144B)
- Income-tax e-filing portal (Form 35, e-proceedings)
- Income Tax Appellate Tribunal — benches and e-filing
Engagement terms for income-tax filing, notices and appeals — reviewed 25 October 2026
- Fee: ITR filing from ₹2,999 + 18% GST. Tax audit under section 44AB from ₹35,000 + 18% GST. Reply to a notice from ₹15,000 + 18% GST. Appeal to CIT(A) from ₹35,000 + 18% GST, with the statutory appeal fee (₹250 to ₹1,000 under section 249) extra.
- Extra / not included: Stay petitions, rectification under section 154 after the appeal, and ITAT appeals are separate engagements. No outcome is guaranteed.
- Turnaround: Notice replies within 7 working days from receipt of complete information and the advance payment and before the compliance date; returns and audit reports by the statutory due date when data is received at least 10 working days before it.
- Who signs: Filings and replies are prepared and signed by V. Viswanathan FCA or another qualified Chartered Accountant of the practice, depending on the engagement.
- Entity: Tax audit reports (Form 3CA/3CB and 3CD) are engaged and invoiced by V Viswanathan & Associates, Chartered Accountants (FRN 013713S); return filing, notice replies and appeal drafting are engaged and invoiced by Virtual Auditor Private Limited.
- What to send first: Send the notice or order with its date of service, Form 26AS/AIS, the return and computation for the year, and the income-tax portal login.
- Next step: Send your enquiry on WhatsApp to +91 99622 60333; we confirm the scope, fee and timeline in writing before work starts.
What has changed in the law — reviewed October 2026
- Income-tax Act, 2025: assented to on 21 August 2025 and in force from 1 April 2026, it replaces the Income-tax Act, 1961 for tax year 2026-27 onward, and the Income-tax Rules, 2026 (notified 20 March 2026) replace the 1962 Rules. Section and rule numbers on this page are those of the 1961 Act and 1962 Rules, which continue to govern assessments, appeals and pending proceedings for assessment years up to 2026-27; for tax year 2026-27 onward the corresponding provisions of the 2025 Act apply, and our engagement letters quote both.
- Angel tax: section 56(2)(viib) of the Income-tax Act, 1961 does not apply from assessment year 2025-26 (Finance (No. 2) Act, 2024), so share premium received from any investor is no longer taxed under that clause. Valuations are still required under separate regimes, each with its own law and signing professional: fair market value under Rule 11UA(1)(c) of the Income-tax Rules, 1962 for section 56(2)(x) in the recipient's hands (net-asset basis for unquoted equity shares); FEMA pricing for a non-resident investor under the FEM (Non-debt Instruments) Rules, 2019, certified by a Chartered Accountant, SEBI-registered merchant banker or practising cost accountant; a registered valuer's report under section 247 of the Companies Act, 2013 and Rule 13 of the Companies (Share Capital and Debentures) Rules, 2014 for preferential allotments under section 62(1)(c); and grant-date fair value of the option under Ind AS 102 for ESOP accounting (reviewed 25 October 2026).