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Chennai North · Broadway Division · Broadway IT Notice Reply

Income Tax Notice Reply in Broadway, Chennai

Professional IT Notice Reply for Broadway businesses near Broadway Bus Terminus — with a documented, audit-ready process

for Broadway businesses balancing growth ambitions with tight statutory compliance with WhatsApp document intake and same-day filed-acknowledgement delivery. Call 9566-068-468.

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Quick Answer

What is the role of Article 226 jurisdiction in income tax matters where statutory appeal is available in Broadway, Chennai?

The High Court's writ jurisdiction under Article 226 of the Constitution is not automatically barred by the existence of a statutory appellate remedy. The Supreme Court in Whirlpool Corporation v. Registrar of Trade Marks and a long line of subsequent authority has held that writ remains available in three classes of cases — breach of fundamental rights, violation of natural justice, and orders without jurisdiction. Tax matters that fit any of these heads — a 148 notice without DIN, a 148A(d) order without supply of material, a 144B assessment without the requested video-conference hearing — are amenable to writ even before the appellate route is exhausted, provided the writ petition is filed promptly.

Transparent Pricing

IT Notice Reply in Broadway — Plans & Pricing

Fixed fees · Zero hidden charges · Call 9566-068-468 for a custom quote.

MonthlyAnnualSave 2 Months
Single notice
Standard
Written reply + documentation
₹5,000/per notice

  • Notice Analysis 143(1) 148 131 etc.
  • AIS / 26AS Reconciliation
  • Written Reply with Supporting Documents
  • CPC Intimation Response 143(1)
  • Scrutiny Notice Reply 143(2)
  • Reassessment Notice 148 / 148A
  • Personal Hearing Attendance
  • Penalty Notice Reply Section 271
  • Demand Stay Application
  • Appeal to CIT(A) Form 35
  • Survey / Search Assistance Sec 133A
Most Popular ⭐
Professional
Reply + Followup + demand review
₹10,000/per notice

  • Notice Analysis 143(1) 148 131 etc.
  • AIS / 26AS Reconciliation
  • Written Reply with Supporting Documents
  • CPC Intimation Response 143(1)
  • Scrutiny Notice Reply 143(2)
  • Reassessment Notice 148 / 148A
  • Personal Hearing Attendance
  • Penalty Notice Reply Section 271
  • Demand Stay Application
  • Appeal to CIT(A) Form 35
  • Survey / Search Assistance Sec 133A
Assessment orders
Litigation
Full litigation support
₹15,000/per notice

  • Notice Analysis 143(1) 148 131 etc.
  • AIS / 26AS Reconciliation
  • Written Reply with Supporting Documents
  • CPC Intimation Response 143(1)
  • Scrutiny Notice Reply 143(2)
  • Reassessment Notice 148 / 148A
  • Personal Hearing Attendance
  • Penalty Notice Reply Section 271
  • Demand Stay Application
  • Appeal to CIT(A) Form 35
  • Survey / Search Assistance Sec 133A

Swipe to see all plans

Prices exclude GST. For enterprise pricing, call 9566-068-468.

Why FilingPro?

Why Broadway Clients Choose FilingPro

Expert IT Notice Reply in Broadway — qualified professionals, 15+ years experience, zero-penalty track record.

Section 154 Rectification Where Faster

Where the issue is a mistake apparent from record — wrong TDS credit, arithmetical error, missed Section 87A rebate, AIS mismatch — Section 154 rectification is filed online within the 4-year window for a faster outcome than appeal.

Section 270AA Immunity Application

Where the assessee accepts the addition, pays tax and interest, and chooses not to appeal, Form 68 application under Section 270AA is filed within 1 month — full immunity from Section 270A penalty and Section 276C / 276CC prosecution.

Vivad se Vishwas 2024 Settlement

interest & penalty waived

Section 253 ITAT Representation

Where CIT(A) order is adverse, Section 253 appeal in Form 36 is filed within 60 days with the prescribed fee (₹500 to ₹10,000 by income slab). Senior counsel is briefed; written submissions and paper book are filed; hearing representation is provided.

Textbook Method Applied

Every matter is approached the way an examiner expects a candidate to answer — issue stated, provision quoted, authority cited, computation tabulated and conclusion reasoned. This pedagogical discipline transfers directly to the quality of the submission.

Limitation Treated Seriously

It is to be noted that limitation is jurisdictional. A defence built on the four-year ceiling of Section 154(7), or on the three-year and ten-year bands of Section 149, is therefore prepared with the same rigour as the merits defence itself.

Key Benefits

What Broadway Clients Get

Every IT Notice Reply engagement delivers measurable, guaranteed outcomes — expert professionals, on time, every time.

Sanction Validity Examined
The sanction of the specified authority under Section 151 is examined for compliance with rank and timing. A reopening proceeding founded on a defective sanction is a textbook ground of invalidity, available both in reply and in any subsequent writ remedy.
Penalty Exposure Mapped
Exposure under Section 270A is mapped at the reply stage itself — the under-reporting limb at fifty per cent and the misreporting limb at two hundred per cent of tax — with arguments structured to keep the matter, where defensible, within the lower limb.
Immunity Pathway Considered
The pathway under Section 270AA, by which immunity from penalty and prosecution may be sought through Form 68 within one month from the end of the month of receipt of the order, is evaluated and recommended where the conditions are objectively satisfied.
Stay Application Prepared
Where demand is raised, an application under sub-section (6) of Section 220 is prepared, drawing upon the Office Memorandum of the Central Board of Direct Taxes dated the thirty-first of July, 2017, particularly the relaxation available where assessment is unreasonably high-pitched.
Pre-Issuance Procedure of Section 148A is Audited Line by Line
Every reopening notice that crosses my desk is taken apart against the four-stage scheme — enquiry under clause (a), show-cause under clause (b), consideration of reply under clause (c), and speaking order under clause (d). Where any stage is skipped, abbreviated below seven days, or signed by an authority not specified for the year under Section 151, the reply records the breach and reserves the right to challenge the resulting 148 notice on jurisdictional grounds.
Section 149 Limitation is Tested Against the Asset Test
The three-year and ten-year limits of Section 149 are applied to the precise facts of the recorded reasons, not to the rhetoric of the notice. Where the alleged escapement is not represented in an asset, expenditure or entry of fifty lakh rupees or more, the ten-year window collapses to three. This computation is reduced to a one-page note and annexed to every reassessment reply so that the limitation defence is preserved on the assessment record itself.
Comparison

Section 148 Old Regime (pre 01-Apr-2021) vs Section 148A New Regime (post 01-Apr-2021)

Why this matters here — In Broadway, the business activity radiating outward from Broadway Bus Terminus and nearby commercial pockets; with quick access via Broadway Bus Terminus and feeder routes connecting Broadway to the rest of Chennai.

AspectSection 148 Old Regime (pre 01-Apr-2021)Section 148A New Regime (post 01-Apr-2021)
Assessee's reply windowStandard thirty-day return-filing window under the notice after the reassessment proceeding had been initiated; merit objections were filed during the reassessment itselfSeven to thirty-day show-cause reply window before the Section 148 notice is even issued; the assessee has an early opportunity to deflect the reopening at the threshold itself
Available remedies post issuanceArticle 226 writ before the jurisdictional High Court attacking the reasons and sanction; pursue reassessment to assessment order followed by Section 246A appeal to CIT(A) and then ITAT under Section 253Article 226 writ challenge to the Section 148A(d) order itself before any Section 148 notice is issued; alternatively, allow Section 148 to issue and proceed to assessment-stage remedies including CIT(A) and ITAT
Penalty exposure on reopened additionsConcealment penalty under the then-Section 271(1)(c) at 100 to 300 per cent of tax sought to be evaded, with Explanation deeming provisions and the burden-of-proof issues addressed in K.P. Madhusudhanan v CITUnder-reporting penalty under Section 270A at fifty per cent of tax payable on under-reported income, escalating to two hundred per cent where misreporting is established; immunity available under Section 270AA on prescribed conditions
Governing statutory architectureReassessment driven by 'reason to believe' under unamended Section 147, with Section 148 notice issued after recording reasons and obtaining sanction under the pre-substitution Section 151Reassessment can be triggered only after a mandatory enquiry-with-show-cause under the substituted Section 148A, culminating in a speaking order under clause (d) before any Section 148 notice may be issued
Threshold standard for reopening'Reason to believe' that income chargeable to tax has escaped assessment — a subjective satisfaction test interpreted by GKN Driveshafts and a long line of High Court precedent'Information suggesting that income chargeable to tax has escaped assessment' as defined in Explanation 1 to Section 148, narrowing the scope to risk-management strategy flags, audit objections and prescribed survey/search material
Procedural pre-notice stepsNo statutory show-cause stage before issue of notice; assessee's procedural rights were judge-made — request reasons, file objections, await speaking order per GKN DriveshaftsFour sub-stages baked into the statute — clause (a) preliminary enquiry, clause (b) show-cause not less than seven days, clause (c) consider reply, clause (d) speaking order on whether reopening is fit
Outer limitation windowFour years where return was processed and full disclosure was made, six years where escaped income was ₹1 lakh or more, sixteen years for foreign assets — governed by unamended Section 149Three years from the end of the relevant assessment year in normal cases, extendable to ten years where alleged escaped income represented by an asset is ₹50 lakh or more — substituted Section 149(1)(a) and (b)
Sanctioning authorityJoint Commissioner sanction for reopening within four years; Principal Commissioner or Chief Commissioner sanction for reopening beyond four years under unamended Section 151Principal Commissioner or Principal Director for reopening within three years; Principal Chief Commissioner or Director General where reopening is beyond three years — substituted Section 151
Treatment of survey-found materialSurvey material under Section 133A formed the basis of fresh assessment after recording reasons; legality often litigated on the question of whether mere survey statements supported 'reason to believe'Survey or search results expressly included as 'information' under Explanation 1 to Section 148; the deeming of escapement under Explanation 2 makes the issuance machinery cleaner but the assessee retains the Section 148A reply opportunity
Notice format and validity testNotice valid if recorded reasons existed on file and sanction was obtained; service had to be effected within limitation; subjective satisfaction was open to challenge but not the form of the noticeNotice valid only if preceded by a Section 148A(d) order; the order itself must consider the assessee's reply and record the basis for deeming the case fit for reopening — non-speaking orders are vulnerable on Kranti Associates principles
Bridging period treatmentOld regime ceased to operate on the substitution date; notices issued between 01-Apr-2021 and 30-Jun-2021 under the old regime were procedurally defective from inceptionSupreme Court in Union of India v Ashish Agarwal (Civil Appeal 3005/2022) deemed those transitional notices to be Section 148A(b) show-cause notices, salvaging the proceedings by giving thirty days for material and reply
Limitation overlay with TOLALimitation under unamended Section 149 was extended by the Taxation and Other Laws Relaxation Act 2020 for notices falling between 20-Mar-2020 and 31-Mar-2021, with successive CBDT notificationsSupreme Court in Union of India v Rajeev Bansal (Civil Appeal 8629/2024) clarified that TOLA extensions tail into the new regime for assessment years 2013-14 to 2017-18 and laid down a stage-by-stage limitation chart
Documents Required

Documents for IT Notice Reply

Share documents via WhatsApp to 9566-068-468. No office visit required for Broadway clients.

Notice copy with DIN — 143(1) / 143(2) / 142(1) / 148 / 148A / 245 / 154 (DIN mandatory under CBDT Circular 19/2019 dated 14-Aug-2019)
Filed ITR (ITR-V acknowledgement) and computation of total income for the AY
Form 26AS download for the relevant AY from TRACES / e-filing portal
AIS (Annual Information Statement) and TIS (Taxpayer Information Summary) PDF
Detailed computation working — head-wise income, deductions, exemptions, tax payable, TDS/TCS/Advance Tax
Supporting evidence — bank statements, capital gains workings, deduction proofs, audit report (Form 3CD/3CB), loan confirmations, investment proofs
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Statutory Deadlines

Compliance deadlines that matter

Miss any of these and the next consequence kicks in automatically.

Deadlines in this neighbourhood — In Broadway, the cluster of wholesale trade, transport, hospitality businesses that defines Broadway's commercial fabric.

Trigger eventDaysFormConsequence
Intimation under Section 143(1) proposing adjustment served on the registered email or Income Tax e-portal30 daysOnline response on e-portal — agree or disagree with each proposed adjustmentProposed adjustment is given effect; revised intimation becomes appealable under Section 246A within thirty days; Section 220(1) demand timeline commences
Section 142(1) inquiry notice asking for return or production of accounts or information15 daysOnline compliance on e-portal with the return / accounts / information soughtSection 271(1)(b) penalty of ten thousand rupees per default; best-judgment assessment under Section 144 follows; Section 276D prosecution exposure for repeated default
Section 148A(b) show-cause notice asking why reassessment notice under Section 148 should not be issued30 daysWritten reply through e-portal addressing each information item cited in the noticeSection 148A(d) order passed without reply; subsequent Section 148 notice and reassessment under Section 147 proceed; objection on jurisdiction available only at writ stage
Section 245 prior intimation proposing adjustment of refund against outstanding demand30 daysOnline disagreement with reasons through e-portal — challenge to existence or correctness of the demandRefund adjusted without recourse; the underlying demand stands undisturbed; the only remaining remedy is Section 154 against the demand order or appeal under Section 246A
Section 156 notice of demand consequent to an order under Section 143(3), 144 or 14730 daysPayment through ITNS-280 challan citing the demand identification number, or stay petition under Section 220(6)Section 220(2) interest at one per cent per month begins; assessee becomes 'in default' under Section 220(4); recovery action under Section 222 read with the Second Schedule may commence
Reply to Section 143(1)(a) prima-facie intimation served by CPC30 dayse-Proceedings response with supporting documentsProposed adjustment becomes final automatically; demand is raised inclusive of interest under Section 234B and 234C; the easier portal-side correction route is closed and the only remaining remedy is a Section 154 rectification or Section 246A appeal within their own limitation windows
Reply to Section 148A(b) show-cause notice in reassessment pre-issuance procedure30 dayse-Proceedings reply with jurisdictional and merits submissionsSection 148A(d) order is passed ex parte; if the order is adverse a Section 148 notice follows immediately and the reassessment proceeding commences with a presumption against the assessee on every issue the show-cause raised but the assessee did not contest at 148A(b) stage
Response to Section 245 refund set-off intimation on portal30 daysOnline response in e-filing 'Response to Outstanding Demand'Set-off becomes final and the current-year refund is permanently adjusted against the alleged demand; reversal thereafter requires a separate Section 154 rectification of the underlying demand and a fresh refund claim, both of which carry their own multi-month processing timelines

Deadline pressure points we see in Broadway: Closer to Broadway, for Broadway businesses balancing growth ambitions with tight statutory compliance.

Forms Library

Forms used in this engagement

Forms most asked about here — In Broadway, where wholesale trade businesses dominate the local compliance profile.

Notice u/s 156Notice of demand

Notice specifying the sum payable in consequence of any order under the Act — tax, interest, penalty, fine; the operative document for recovery; payable within thirty days under Section 220(1)

Served along with order giving rise to the demand Jurisdictional Assessing Officer / Faceless Assessment Centre
Form 35Appeal to Commissioner (Appeals)

Electronic form for filing first appeal under Section 246A against assessment, reassessment, rectification or penalty orders; carries grounds of appeal, statement of facts, and proof of fee payment

Within thirty days of service of order appealed against — Section 249(2)(b) Commissioner of Income-tax (Appeals) / National Faceless Appeal Centre
Form 36Appeal to Income Tax Appellate Tribunal

Memorandum of appeal to ITAT under Section 253 against orders of Commissioner (Appeals), Commissioner under Section 263 or 264, or penalty orders by Principal Commissioner; filed in triplicate with certified order copy

Within sixty days of communication of the order appealed against — Section 253(3) Income Tax Appellate Tribunal — Chennai Bench at Madras Mahal
Form 68Application for immunity from penalty under Section 270A

Application seeking immunity from imposition of penalty under Section 270A and prosecution under Section 276C and Section 276CC, conditional on payment of tax and interest as per order and non-filing of appeal

Within one month from end of month in which the order is received — Section 270AA(2) Jurisdictional Assessing Officer
ITR-UUpdated return under Section 139(8A)

Updated return enabling any person to disclose income previously omitted; accompanied by proof of payment of additional tax under Section 140B — twenty-five per cent or fifty per cent of tax and interest depending on year of filing

Within twenty-four months from end of relevant assessment year e-filing portal — Centralised Processing Centre
Challan ITNS-280Challan for payment of income tax — self-assessment, advance tax, regular assessment

Challan for remitting tax demand consequent to Section 156 notice, self-assessment tax under Section 140A, advance tax instalments, or regular assessment dues; carries assessment year, demand identification number where applicable

Within thirty days of Section 156 demand to avoid Section 220(2) interest Authorised banks / e-Pay Tax portal
Stay petition u/s 220(6)Application for stay of recovery pending appeal

Written application before Assessing Officer seeking treatment as not being in default during pendency of Section 246A appeal; per CBDT OM, twenty per cent pre-deposit ordinarily required to qualify

Filed within Section 220(1) thirty-day demand window or immediately on filing of appeal Jurisdictional Assessing Officer; further stay before ITAT under Section 254(2A) where matter is before ITAT
Notice u/s 143(1)Intimation under Section 143(1) — Centralised Processing Centre

System-generated intimation processed by CPC Bengaluru that communicates either acceptance of the return as filed, refund determined, or proposed adjustments under clauses (i) to (vi) of Section 143(1)(a) requiring response within thirty days

Issued within nine months from end of financial year of return filing — Section 143(1) proviso Centralised Processing Centre, Bengaluru

IT Notice Reply in Broadway, Chennai 600001

Businesses registered in Broadway share the Chennai North jurisdiction, and their statutory matters route through the same Broadway Division each time. We keep a cycle-by-cycle record of how the Broadway Division of the Chennai North handles Broadway filings and approvals. Broadway (PIN 600001) falls under the Broadway Division of the Chennai North, the jurisdiction that handles statutory matters for businesses at this PIN. Broadway is the central transport interchange for north Chennai with wholesale shops freight forwarders and budget hotels surrounding the bus terminus.

Most commerce in Broadway — invoices, expenses, purchases and statutory records — eventually surfaces in the IT Notice Reply working file we maintain for clients here. The central transport and wholesale hub mix of Broadway shapes what lands in our workpapers — a blend of hospitality activity and the commercial pulse around Burma Bazaar. Freight and foot traffic from the Broadway Bus Terminus hub pull steady daily commerce through Broadway, so there is rarely a quiet filing month in this central transport and wholesale hub pocket. Broadway sustains a high flow of commerce for a central transport and wholesale hub locality, and that flow is the raw material for the IT Notice Reply files we close here.

The business mix in Broadway centres on transport, and that sector carries its own IT Notice Reply quirks we plan for in advance. For a transport business in Broadway, the IT Notice Reply scope is rarely generic; we tailor the checklist to how that sector actually transacts. transport units around Broadway share recurring IT Notice Reply patterns — input-credit timing, vendor reconciliation, and sector-specific documentation. Sector concentration matters: when Broadway leans toward transport, the IT Notice Reply risks cluster around the same few line items each cycle.

Document intake for Broadway clients runs over WhatsApp, so there is no office visit and no paper shuffle for a IT Notice Reply engagement. The qualified-review step on every Broadway IT Notice Reply file is where errors get caught before they reach the portal. Turnaround for Broadway IT Notice Reply is deterministic — fixed fee, a scoped timeline, and a same-business-day acknowledgement once filed. Working papers for Broadway IT Notice Reply engagements stay archived and retrievable, which makes any later notice or query straightforward to answer.

Coverage from Broadway naturally extends to Parrys Corner, so group entities across the area share one IT Notice Reply workflow. A client relocating between Broadway and Parrys Corner keeps the same IT Notice Reply file and the same team. Proximity to Parrys Corner means a Broadway engagement can extend across the locality cluster with no change in cadence. We treat Broadway and Parrys Corner as one catchment for IT Notice Reply, which keeps documentation and turnaround consistent.

Patterns we track for Broadway include hospitality documentation gaps, timing mismatches, and the questions the Broadway Division tends to raise. The IT Notice Reply mistakes we see most in Broadway are avoidable with disciplined intake, which our checklist enforces. Because we work repeatedly across Broadway, we can benchmark a new client's IT Notice Reply position against the locality norm. Recurring gaps in Broadway hospitality records are the first thing our IT Notice Reply review closes out.

A startup setting up near Madras High Court in Broadway gets a IT Notice Reply foundation built for the Broadway Division from day one. New transport ventures in Broadway lean on us to stand up IT Notice Reply correctly before the first deadline rather than after a notice. When a George Town business expands into Broadway, we extend its IT Notice Reply setup to PIN 600001 without disruption. We onboard new Broadway entities onto a IT Notice Reply cadence that is audit-ready from the very first cycle.

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Expert Guide

IT Notice Reply in Broadway — Complete Guide

On a single notice, the working folder carries the original PDF with DIN authenticated, the e-Proceedings transaction log, AIS and TIS downloads as on date of reply, Form 26AS, the source documents being relied on, the draft reply with annexure index, the partner-signed final reply, and the upload acknowledgement. Where the matter goes to scrutiny under 144B, we add the questionnaire chain, the draft assessment order, the show-cause reply and the video-hearing minutes. The folder is closed only when the order is final or the appeal is lodged.

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Qualified professionals handle your IT Notice Reply in Broadway. WhatsApp documents — we begin within 24 hours. From ₹3,000/per-notice. Free consultation.
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Key Facts — IT Notice Reply in Broadway
Section 143(1)(a) prima facie adjustment reply within the 30-day window — 26AS / AIS / TIS reconciled and contested item by item
Section 143(2) scrutiny notice replied through Section 144B Faceless Assessment portal with Section 142(1) questionnaire submissions
Section 148A(b) show-cause replied within 7-30 days; Section 148A(d) speaking order analysed for sanction under Section 151 and time-limit defence
Section 148 reassessment defence applying Finance Act 2021 regime, ₹50 lakh threshold and Ashish Agarwal / Rajeev Bansal Supreme Court rulings
Section 245 set-off intimation responded within 21 days — outstanding demand contested with assessment order, challan or appeal pendency proof
Section 154 rectification filed online for arithmetical error, missed TDS credit, AIS mismatch — within 4 years from end of FY of order
Section 270A under-reporting and misreporting penalty contested; Section 270AA immunity application filed in Form 68 where conditions met
Section 250 CIT(A) appeals in Form 35 routed through Faceless Appeal Centre; Rule 46A additional evidence petitions drafted with reasons
Section 220(6) stay of demand petitions with 20% deposit; high-pitched assessment exception per CBDT OM 31-Jul-2017 invoked where applicable
Vivad se Vishwas 2024 settlement evaluated for pending appeals — disputed tax computed, declaration in Form 1, Form 3 evidence of payment filed
People Also Ask — IT Notice Reply in Broadway
How long do I have to reply to a Section 143(1)(a) notice?
30 days from the date of intimation. The reply is filed online under e-Proceedings on incometax.gov.in. Silence is treated as acceptance of the proposed adjustment.
Is personal hearing allowed in faceless assessment?
Yes. Section 144B(6)(viii) read with the Faceless Assessment Scheme guarantees personal hearing by video conference where the assessee requests it after a draft assessment order with show-cause is issued. Denial vitiates the order on natural-justice grounds.
What is the time limit for Section 148 notice under the new regime?
3 years from the end of the relevant assessment year in normal cases; extended to 10 years where the AO has books of account, documents or evidence revealing escaped income represented in the form of asset, expenditure or entry exceeding ₹50 lakh — Section 149 read with Section 148 as substituted by Finance Act 2021.
Can refund be adjusted against demand without my knowledge?
No. Section 245 mandates prior intimation of 21 days before any set-off. Adjustment without pre-intimation is liable to be set aside; respond through 'Pending Actions > Outstanding Demand' on e-filing portal.
What is the difference between Section 143(1) intimation and Section 143(3) assessment order?
Section 143(1) is centralised computer processing of the return by CPC with prima facie adjustments. Section 143(3) is scrutiny assessment after issue of Section 143(2) notice, examination of evidence under Section 144B and a speaking order.
What if no DIN is mentioned on the notice?
Per CBDT Circular 19/2019 dated 14-Aug-2019, communication issued by income tax authority without DIN is treated as invalid and non est. Authenticate DIN at incometax.gov.in under 'Authenticate Notice/Order' before responding.
What is the role of e-Nivaran in income-tax notice handling?

e-Nivaran is the grievance-redressal portal accepting complaints on refund delay, demand misposting, Section 245 mis-adjustment, AS-26 discrepancies and PAN-related issues. It complements the formal Section 154/246A routes and often achieves quicker administrative correction.

How is AIS feedback used to defend a Section 143(1)(a) intimation?

AIS feedback options — 'duplicate', 'relates to other person', 'already offered earlier' — allow the assessee to flag entries that have been misclassified or double-counted. The feedback is considered in the next AIS refresh and forms supporting material for the 143(1)(a) reply.

What is Section 144B faceless assessment scheme?

Section 144B introduced by the Finance Act 2021 mandates that all assessments under Sections 143(3) and 144 are conducted faceless through the National Faceless Assessment Centre with Assessment Unit, Verification Unit, Technical Unit and Review Unit roles distributed nationally.

What is the Section 142(2A) special audit and when is it invoked?

Section 142(2A) empowers the AO, with prior approval of Pr.CIT, to direct a special audit by a chartered accountant where the accounts are complex or doubts arise on correctness. The Section 142(2C) report becomes the basis for further assessment proceedings.

Can the Section 142(2A) special-audit direction be challenged?

Yes — by writ before the High Court on grounds of mala fide or non-application of mind. The Supreme Court has held that the AO must record valid reasons demonstrating complexity, and the assessee must be heard before the direction. Sahara India is the leading precedent.

What is the Section 119(2)(b) condonation of delay route?

Section 119(2)(b) read with CBDT Circular 9 of 2015 allows condonation of delay in filing returns claiming refund or carry-forward of loss. The Pr.CIT/CCIT/CBDT — depending on quantum — exercises this discretion on hardship grounds with documentary support.

What Broadway clients want to know before signing: Closer to Broadway, in the central transport and wholesale hub micro-market of Broadway, which is why where wholesale trade businesses dominate the local compliance profile.

Expert Guide

A complete walkthrough — Income Tax Notice Reply

Localised for Broadway, Chennai — where wholesale trade businesses dominate the local compliance profile.

Reading this guide locally — In Broadway, on the Parrys Corner-Sowcarpet corridor that passes through Broadway.

What is an income tax notice and what triggers it

Service of notice and digital infrastructure

Section 282 read with Rule 127 governs the mode and place of service of any notice under the Act. Electronic service through the e-filing portal, the registered email, and (where applicable) the mobile number registered with the department is the primary mode under the Faceless framework, with physical service preserved as a backup. The Pradeep Goyal Supreme Court ruling on the Document Identification Number mandate, codified through CBDT Circular 19/2019, requires every notice and order to carry a DIN that can be verified on the e-filing portal — a notice without a verifiable DIN is treated as invalid except in narrow exceptional circumstances. The Anshul Jain Delhi HC ruling and the Tata Communications Bombay HC ruling have applied the DIN requirement strictly, with the assessee entitled to seek verification before responding substantively. Service through the e-Proceedings module triggers the compliance window from the date of dispatch, not the date of access by the assessee, making prompt portal review critical.

Reading the notice — what to identify first

Any reply strategy begins with a structured reading of the notice itself. The first identification is the section under which the notice has been issued, since this determines the procedural framework and the compliance window. The second is the assessment year to which the notice relates, since the limitation provisions under Section 149, Section 153, and Section 154 are computed by reference to assessment year boundaries. The third is the Document Identification Number, which must be verified through the e-filing portal. The fourth is the response deadline stated on the face of the notice. The fifth is the specific information sought or adjustment proposed, which determines the substantive content of the reply. The sixth is the jurisdiction — faceless under Section 144B versus territorial under Section 124 — since this affects appellate routing under Section 246A and writ jurisdiction under Article 226 before the appropriate High Court.

Statutory framework and notice typology

An income tax notice is a formal communication issued by the income tax authorities under the Income-tax Act 1961 conveying an action, requirement, or finding affecting the recipient's tax position. The Act provides for several distinct categories of notice — intimation under Section 143(1) after return processing, inquiry under Section 142(1) seeking information, scrutiny under Section 143(2) opening an assessment, reassessment under Section 148 read with the post-April-2021 Section 148A framework, rectification under Section 154, adjustment under Section 245, demand under Section 156, and recovery under Section 220 and Section 222. The Central Board of Direct Taxes prescribes the form, content, and procedural requirements for each notice through Rules under Section 295 and contemporaneous Circulars. The Faceless Assessment Scheme under Section 144B routes most communications through the National Faceless Assessment Centre, with notices served electronically through the e-filing portal and the registered email under Rule 127. Each notice carries distinct compliance windows, substantive content requirements, and consequence patterns, making accurate identification of the section under which the notice has been issued the first analytical step in any reply strategy.

Section 147 and 148 pre-2021 reassessment framework

Transitional reassessments and the Ashish Agarwal ruling

The Finance Act 2021 substituted Section 147 and Section 148 with the new Section 148A framework effective 1 April 2021. The Supreme Court in Union of India v Ashish Agarwal (2022) addressed the transitional question of notices issued under the old Section 148 between 1 April 2021 and 30 June 2021 — the court directed that such notices be treated as Section 148A(b) show-cause notices under the new framework, with the procedural protections of Section 148A made available retrospectively. The Rajeev Bansal Supreme Court ruling (2024) further clarified the limitation interaction between the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act 2020 and the new framework. The transitional jurisprudence applies to several pending reassessments and remains relevant for assessees with notices issued in the transition window, with the response strategy involving the Section 148A(b) framework and the documented limitation working.

GKN Driveshafts response architecture

The GKN Driveshafts (India) v ITO Supreme Court ruling (2003) established a procedural architecture for responding to Section 148 reassessment notices that retains direct relevance even under the post-2021 framework. The architecture has three steps — first, the assessee files the return in response to the Section 148 notice within the time stipulated; second, the assessee requests a copy of the reasons recorded by the Assessing Officer for the reopening; third, the assessee files objections to the reasons in writing; fourth, the Assessing Officer is required to dispose of the objections through a speaking order before proceeding with the reassessment. Failure of the Assessing Officer to follow the architecture is fatal to the reassessment as held in subsequent rulings. The architecture survives in the post-2021 framework through Section 148A(b) and (d), with the show-cause and the order on the show-cause performing equivalent procedural functions.

Writ remedy under Article 226 before Madras High Court

Reassessment notices that suffer from jurisdictional defects — issuance without reasons recorded, mere change of opinion, expiry of limitation, sanction not obtained from the prescribed authority under Section 151 — are challengeable through Article 226 writ before the Madras High Court for assessees with Tamil Nadu jurisdiction. The Calcutta Discount Co Supreme Court ruling, the Madhya Pradesh Industries Supreme Court ruling, and several Madras High Court rulings have applied the writ remedy to set aside reassessment notices at the threshold without requiring the assessee to first exhaust the appellate hierarchy. The writ route is appropriate where the defect is patent and the alternative remedy is inadequate, particularly given the prolonged stay risk during the appellate process under Section 220(6). The strategic choice between the appellate route and the writ route depends on the nature of the defect and the documentary state of play.

Section 148A post-April-2021 reassessment framework

Statutory architecture and procedural safeguards

Section 148A inserted by the Finance Act 2021 effective from 1 April 2021 introduced a four-step procedural architecture preceding any Section 148 reassessment notice. Section 148A(a) provides for inquiry, if required, with the prior approval of the specified authority. Section 148A(b) provides for a show-cause notice to the assessee seeking response on why a Section 148 notice should not be issued, with the assessee given seven to thirty days to respond. Section 148A(c) requires the Assessing Officer to consider the assessee's reply. Section 148A(d) requires the passing of an order, with the approval of the specified authority, deciding whether or not it is a fit case for issue of a Section 148 notice. The architecture is procedural rather than substantive, with the substantive reassessment occurring through the subsequent Section 148 notice and Section 147 assessment. The framework substantially strengthens the assessee's procedural position relative to the pre-2021 regime.

Information triggers and Section 135A

The post-2021 framework requires the Assessing Officer to have information suggesting income escaping assessment before invoking the Section 148A procedure. Explanation 1 to Section 148 lists the categories of information including risk-management strategy notified by the Board, audit objections, information received under Section 90 or Section 90A, communication from any law-enforcement agency, and information received under a scheme notified under Section 135A. The Section 135A faceless inquiry scheme provides for an Inquiry and Verification Centre to collect information that the Assessing Officer can rely on. The framework moves from the subjective reason-to-believe standard of the pre-2021 regime to an objective information-based standard, with the assessee's response strategy focused on rebutting the underlying information rather than challenging subjective formation of belief.

Drafting the Section 148A(b) response

The Section 148A(b) response is the critical procedural opportunity for the assessee to avoid the subsequent Section 148 reassessment. The response is drafted addressing the information cited in the show-cause notice and demonstrating either that the information does not suggest income escaping assessment or that the assessee has a documentary answer to the underlying transaction. The covering letter identifies the notice, the assessment year, and the response deadline. The substantive content engages with each piece of information cited, providing documentary substantiation. Where the information is patently incorrect, this is articulated transparently with supporting evidence (FIRC for foreign remittances, bank statement classification for deposits, GST documentation for cross-tax-base entries). The response is uploaded through the e-Proceedings portal with the acknowledgement number retained. The substantive engagement at the Section 148A(b) stage substantially improves the prospects of a favourable Section 148A(d) order.

Section 149 limitation framework

Limitation for foreign-asset cases under Section 149(1)(c)

Section 149(1)(c) as it stood prior to the Finance Act 2021 prescribed a sixteen-year limitation for reassessments involving assets located outside India. The post-2021 framework consolidates this within the ten-year limit under Section 149(1)(b) where the asset value crosses fifty lakh rupees, with the foreign-asset character no longer triggering a distinct longer window. For transitional cases involving foreign assets reported under the Foreign Asset Reporting framework or detected through the Common Reporting Standard exchange of information, the limitation working draws on the assessment year of escapement, the asset value, and the TOLA extension. The Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act 2015 provides a separate parallel framework for foreign undisclosed assets with its own limitation provisions under Section 11 of that Act, which operate independently of the Section 149 framework.

Post-2021 limitation periods

Section 149 as substituted by the Finance Act 2021 prescribes the limitation periods for issuance of Section 148 reassessment notices. The general limitation under Section 149(1)(a) is three years from the end of the relevant assessment year. The extended limitation under Section 149(1)(b) is ten years from the end of the relevant assessment year where the income escaping assessment, represented in the form of an asset or expenditure or entry, is or is likely to be fifty lakh rupees or more. The Section 149(1A) framework prescribed for asset-based escapement requires the existence of the asset to be evidenced through specified means. The structure substantially limits the routine reassessment window compared to the pre-2021 framework, with the ten-year extension reserved for high-value cases. The limitation begins from the end of the assessment year, making the working of the cut-off date analytically straightforward.

TOLA interaction and the Rajeev Bansal ruling

The Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act 2020 extended limitation periods for various income-tax actions during the pandemic period, with the interaction between TOLA and the substituted Section 149 producing significant jurisprudence. The Rajeev Bansal Supreme Court ruling (2024) addressed the question of which limitation period applies to notices issued in the transition window — TOLA-extended pre-2021 limitation or the substituted post-2021 limitation. The court harmonised the two regimes with detailed working for each combination of original assessment year and issue date. The framework requires assessees with reassessment notices in the transition or post-transition window to undertake a precise limitation working drawing on the TOLA extension dates, the substituted Section 149 periods, and the Rajeev Bansal ruling. Where the working shows limitation expiry, the writ remedy under Article 226 is the most effective route.

What Broadway clients usually ask next: Closer to Broadway, where wholesale trade businesses dominate the local compliance profile, which is why for Broadway businesses balancing growth ambitions with tight statutory compliance.

Glossary

Plain-English glossary for this service

Terms you will hear in this area — In Broadway, where wholesale trade businesses dominate the local compliance profile.

Demand identification number

Demand identification number is the unique number assigned to every demand raised on the e-portal — flowing from Section 143(1) intimations, Section 143(3) assessments, Section 147 reassessments, Section 154 rectifications, or penalty orders. The DIN is the reference for payment, stay petitions and appeal.

Document identification number

Document identification number is the system-generated unique number that, per CBDT Circular 19/2019, must be quoted on every notice, order and communication issued by the Department from 1 October 2019. Communications without DIN are non-est, as held by the Supreme Court in CIT v Brandix Mauritius Holdings.

Section 250 appellate procedure

Section 250 appellate procedure governs the conduct of first appeal before Commissioner (Appeals) — fixation of hearing, opportunity to appellant and AO, further inquiry where considered fit, and disposal preferably within one year from end of financial year of filing. The faceless appeal scheme operates under sub-section (6B).

Stay petition under Section 220(6)

Stay petition under Section 220(6) is the application before the Assessing Officer seeking treatment as not being in default during pendency of Section 246A appeal. CBDT Office Memorandum F. No. 404/72/93-ITCC prescribes twenty per cent pre-deposit ordinarily; departure requires recorded reasons.

Section 220(2) interest

Section 220(2) interest is the simple interest at one per cent for every month or part of a month accruing on the demand from the day immediately following the end of the period under Section 220(1) — typically the thirty-first day from service of the Section 156 demand. Continues until the date of payment.

Section 234A interest

Section 234A interest is the one per cent per month or part of a month interest for default in furnishing return of income, reckoned from the day following the due date under Section 139(1) up to the date of furnishing the return — or where no return is furnished, up to the date of completion of the assessment.

Section 234B interest

Section 234B interest is the one per cent per month interest for default in payment of advance tax — where the assessee has not paid advance tax, or where the advance tax paid is less than ninety per cent of the assessed tax. Reckoned from 1st April of the assessment year to the date of regular assessment.

Section 234C interest

Section 234C interest is the deferment interest for default in payment of instalments of advance tax during the previous year — specific cut-offs of fifteen, forty-five, seventy-five and one hundred per cent at four quarterly instalments. Computed at one per cent per month for three months for each instalment shortfall.

Limited scrutiny

Limited scrutiny is the scrutiny under Section 143(2) where the issues to be examined are confined to specific points flagged by the CASS — typically two or three issues such as cash deposits, deduction claims, mismatch with Form 26AS. Expansion to complete scrutiny requires written approval of the Principal Commissioner.

Complete scrutiny

Complete scrutiny is the scrutiny under Section 143(2) where all aspects of the return may be examined — turnover, expenses, depreciation, loans, additions to capital, partner remuneration. Selected based on CASS criteria or converted from limited scrutiny on approval of the Principal Commissioner.

Form 26AS

Form 26AS is the annual tax statement maintained at the Centralised Processing Centre Bengaluru consolidating TDS, TCS, advance tax, self-assessment tax, refunds, high-value transactions, and specified financial transactions reported by reporting entities. Routinely cited in notice proceedings to anchor income additions.

Annual Information Statement

Annual Information Statement is the comprehensive statement introduced in 2021 displaying information received by the Department from various reporting sources — banks, mutual funds, registrars, employers — covering interest, dividends, sale of securities, sale of property, foreign remittances. Forms the trigger dataset for many Section 142(1) and Section 148A(b) notices.

Cost of Non-Compliance

Real-world penalty exposure

Numerical examples showing tax + interest + penalty across common default scenarios.

ScenarioBase taxInterestPenaltyTotal
Section 271E penalty for repaying cash loan of ₹3 lakh in violation of Section 269TNot applicableNot applicable₹3,00,000 (Section 271E at amount equal to the loan repaid in cash)₹3,00,000
Section 271GA failure to maintain information of reportable account (FATCA/CRS) — financial institution penaltyNot applicableNot applicable₹50,000 (Section 271GA flat amount)₹50,000
Failure to reply to Section 143(1)(a) prima-facie adjustment notice within 30 days; AIS-mismatch addition of ₹2 lakh finalised₹62,400 (₹2,00,000 × 31.2 per cent)₹4,992 (Section 220(2) at 1 per cent per month × 8 months)₹31,200 (Section 270A under-reporting at 50 per cent of tax)₹98,592
Non-response to Section 142(1) inquiry notice; Section 144 best-judgment addition of ₹8 lakh sustained at appeal stage₹2,49,600 (₹8,00,000 × 31.2 per cent)₹44,928 (Section 234B at 1 per cent per month × 18 months)₹40,000 (Section 272A(1)(d) at ₹10,000 × 4 defaults plus Section 270A at ₹1,24,800)₹4,59,328 including Section 270A under-reporting penalty
Section 148 reassessment addition of ₹14 lakh for AY 2019-20 sustained after CIT(A); under-reporting penalty under Section 270A invoked₹4,36,800 (₹14,00,000 × 31.2 per cent)₹2,09,664 (Section 234B 1 per cent × 48 months plus Section 220(2))₹2,18,400 (Section 270A at 50 per cent of tax)₹8,64,864
Misreporting case under Section 270A(9) — false claim of Section 80G donation of ₹4 lakh₹1,24,800 (₹4,00,000 × 31.2 per cent)₹14,976 (Section 234B 1 per cent × 12 months)₹2,49,600 (Section 270A at 200 per cent of tax for misreporting)₹3,89,376

How Broadway businesses typically avoid these: Closer to Broadway, the business activity radiating outward from Broadway Bus Terminus and nearby commercial pockets, which is why for Broadway businesses balancing growth ambitions with tight statutory compliance.

By Industry

Industry-specific patterns in Broadway

How the local trade mix shapes this — In Broadway, where wholesale trade businesses dominate the local compliance profile; the business activity radiating outward from Broadway Bus Terminus and nearby commercial pockets.

Retail
Common issue: Retail proprietorships operating point-of-sale terminals often receive Section 142(1) inquiry notices seeking substantiation of the six-percent-versus-eight-percent Section 44AD presumptive rates applied to digital and cash receipts respectively. The Assessing Officer typically requires payment-gateway settlement reports and POS reconciliation to verify the bifurcation declared in Schedule BP of ITR-4 with the proviso to Section 44AD(1) applied correctly.
How we handle it: Compile payment-gateway settlement statements and POS terminal reports segregating digital from cash receipts; prepare a monthly bifurcation working that reconciles to the annual Schedule BP entries; produce the response within the Section 142(1) deadline with the payment-gateway reports cross-referenced to the bank statement credits; retain the supporting working under Rule 6F for six assessment years from the end of the relevant assessment year.
Retail
Common issue: Retail traders maintaining inventory frequently receive Section 143(1)(a) intimations proposing prima facie adjustments where the closing-stock figure in Schedule BP differs from the audit report Form 3CD clause 14(b) ICDS II disclosure on inventory valuation. The CPC adjustment mechanism flags such mismatches systematically, particularly where slow-moving stock has been written down to net realisable value without aligned disclosure.
How we handle it: Respond within thirty days enclosing the audit report Form 3CD clause 14(b) and the ICDS II inventory valuation working; document the basis for any net-realisable-value writedown with reference to ICDS II paragraph 9 and the contemporaneous working file; where the adjustment is unsustainable, escalate to Section 154 rectification with the apparent-error articulation, citing the OECD Forum on Tax Administration guidance on inventory valuation cross-tax-base alignment.
Hospitality
Common issue: Restaurant proprietorships and small hotel partnerships filing under Section 44AD frequently receive Section 142(1) inquiry notices where the GSTR-3B outward-supply aggregate exceeds the ITR-4 turnover by margins exceeding the timing-difference threshold flagged by the Computer-Assisted Scrutiny Selection algorithm. The Assessing Officer's questionnaire calls for monthly reconciliation between the two figures.
How we handle it: Prepare a month-wise reconciliation tracing each GSTR-3B outward-supply figure to invoice issuance under GST (accrual) and the corresponding receipt collection for cash-basis income tax recognition; document advance receipts that are GST-taxable but not income-tax-recognised in the same year; submit the response on the e-Proceedings portal within the Section 142(1) deadline; transition to ITR-3 with accrual books under Section 145(1) if the gap is structural.
Auto Components
Common issue: Auto component manufacturers operating as tier-2 OEM suppliers receive Section 148A inquiry notices under the post-April-2021 reassessment framework where the income tax department flags information from the GSTN data lake or third-party reports under Section 135A. The Section 148A(b) show-cause notice requires the assessee to respond within seven to thirty days, with the Assessing Officer required to pass a Section 148A(d) order before issuing the Section 148 reassessment notice.
How we handle it: On receipt of the Section 148A(b) notice, examine the underlying information shared and prepare a documented response within the deadline addressing each ground of escape; cite the Ashish Agarwal Supreme Court ruling on transitional Section 148A applicability where relevant; where the Section 148A(d) order is adverse, prepare the response to the subsequent Section 148 reassessment with documentary substantiation; preserve the Article 226 writ remedy before the Madras High Court for jurisdictional defects.
Healthcare
Common issue: Medical practitioners running standalone clinics and consulting independently across hospitals frequently receive Section 143(1)(a) intimations proposing adjustment where the Section 194J TDS aggregate in Form 26AS exceeds the gross receipts declared under Section 44ADA in ITR-4. The CPC adjustment mechanism flags this systematically since hospital deductors report gross professional fees while the practitioner may have reported only the net retained portion.
How we handle it: Respond within the thirty-day window enclosing hospital remittance statements showing the gross-versus-net bifurcation; reconcile each Section 194J entry in Form 26AS to the corresponding hospital arrangement; revise the return under Section 139(5) if the gross receipts declaration was incorrect, before the second proviso deadline; where the gross approaches seventy-five lakh rupees, transition out of Section 44ADA into ITR-3 with audited books under Section 44AB(b).
Case Studies

Anonymised engagements we have handled

Real client situations (names changed); illustrative of the kind of work we do.

A flavour of cases we handle nearby — In Broadway, where wholesale trade businesses dominate the local compliance profile.

Section 149 thresholdHospitality

Section 148 reopening below ₹50 lakh threshold quashed under Section 149(1)(b)

Issue: A boutique restaurant owner received a Section 148 notice for AY 2017-18 alleging escaped income of ₹34 lakh based on purported cash sales suppression. The notice was issued in May 2023, more than three years from the end of the relevant assessment year, and the alleged escaped income did not cross the ₹50 lakh threshold needed for reopening beyond three years.
Approach: Filed a writ under Article 226 before the Madras HC squarely on the limitation point — substituted Section 149(1)(b) permits reopening beyond three years only where the income chargeable to tax represented in the form of an asset, expenditure or entry is ₹50 lakh or more. The department's case at ₹34 lakh fell short. We did not argue merits at all; the entire petition was a limitation challenge.
Outcome: Madras HC quashed the Section 148 notice and the consequential Section 148A(d) order; the department conceded the threshold position; no addition; client recovered approximately ₹85,000 of refund withheld during the pendency.
Section 132BHospitality

Section 132B release of seized cash for self-assessment tax

Issue: A restaurant owner had ₹14 lakh of cash seized during a Section 132 search at his premises. He wished to apply the seized cash towards self-assessment tax liability for AY 2024-25 of approximately ₹4.8 lakh, but the department was treating the entire seized amount as quarantined pending assessment.
Approach: Filed an application under the first proviso to Section 132B(1)(i) requesting release of the seized cash to the extent of the existing self-assessment tax liability. Supported with the computation of admitted income, the original ITR acknowledgement and a request that the balance continue under seizure pending assessment. Relied on the Madras HC ruling that an existing-liability adjustment under Section 132B is to be effected on application, not at the department's discretion.
Outcome: ₹4.8 lakh was released and applied towards the self-assessment tax; client's return processed without demand on that count; the balance ₹9.2 lakh remained under seizure pending assessment, which was later adjusted against assessed liability.
Section 245 proceduralRetail

Section 245 set-off pre-intimation procedural challenge

Issue: A small retail trader's refund of ₹56,000 for AY 2024-25 was silently adjusted against a demand of ₹38,000 for AY 2019-20 that he believed had already been satisfied by a challan paid in March 2022. The Section 245 intimation had been generated but lay un-noticed in the e-portal alerts folder, and the twenty-one-day window had expired by the time the adjustment came to light.
Approach: Filed a Section 154 rectification application annexing the original challan and challan-verification screen captures showing the earlier payment had been credited against the AY 2019-20 demand. Parallel grievance on e-Nivaran flagged the failure of the alert mechanism. Argued that even if the twenty-one-day window had technically expired, the assessee could establish that the underlying demand did not exist on the adjustment date.
Outcome: CPC accepted the rectification, reversed the adjustment, and released the ₹56,000 refund with Section 244A interest; the AY 2019-20 demand was simultaneously marked as nil; client briefed on the importance of weekly e-portal pending-action review.
Section 133A surveyRetail

Survey under Section 133A — voluntary disclosure renegotiated

Issue: During a Section 133A survey at a Chennai jewellery retailer's premises, the proprietor under stress signed a disclosure statement admitting unaccounted sales of ₹84 lakh for FY 2022-23. Subsequent review revealed that ₹56 lakh of the admitted amount represented stock on consignment from a related party — not unaccounted sales — and the admission was therefore overstated.
Approach: Filed a retraction-and-explanation petition before the Pr.CIT recording that the original Section 133A statement had been signed under pressure of survey conditions and that subsequent reconciliation established the related-party-consignment position. Relied on the line of Supreme Court and Madras HC precedents holding that a Section 133A admission does not have evidentiary value comparable to a Section 132(4) sworn statement and can be retracted with supporting material.
Outcome: The Pr.CIT directed the AO to verify the consignment documentation; on verification, ₹56 lakh of the original ₹84 lakh disclosure was excluded; assessment was framed on the residual ₹28 lakh; client saved approximately ₹17 lakh of tax-and-interest exposure compared to the original admission.

Why these Broadway engagements look the way they do: Closer to Broadway, the business activity radiating outward from Broadway Bus Terminus and nearby commercial pockets, which is why for Broadway businesses balancing growth ambitions with tight statutory compliance.

Client Reviews

What Broadway Clients Say

Section 148 reassessment quashed — limitation
IT Notice Reply
“Notice for AY 2016-17 issued in Aug-2023 invoking the 10-year limit. We demonstrated escaped income did not cross ₹50 lakh threshold and that sanction under Section 151 was from the wrong authority. Section 148A(d) order set aside on writ; reassessment dropped.”
Verified Client
Limited scrutiny defended — addition deleted
IT Notice Reply
“CASS-flagged scrutiny under Section 143(2) on bogus LTCG. Filed share register, demat statements, STT-paid contract notes and AO's own remand findings. Faceless Assessment Unit accepted explanation; addition of ₹38 lakh deleted in Section 143(3) order.”
Verified Client
Section 270A penalty reduced from 200% to 50%
IT Notice Reply
“AO levied 200% misreporting penalty on disallowance of expenses. Argued the disallowance was on a debatable issue — possible-view doctrine — not misreporting. Faceless Penalty Centre accepted plea; penalty restricted to 50% under-reporting. Saved ₹4.6 lakh.”
Verified Client
Section 245 adjustment reversed — refund released
IT Notice Reply
“CPC adjusted ₹2.1 lakh refund of AY 2024-25 against an old AY 2018-19 demand that was already stayed by CIT(A). Filed disagreement on outstanding demand portal with stay order; refund released within 6 weeks.”
Verified Client
Section 143(1)(a) adjustment of HRA exemption reversed
IT Notice Reply
“CPC proposed adjustment disallowing HRA citing AIS mismatch. Filed reply within 30 days with rent receipts, landlord PAN, bank rent payment trail and revised computation. Adjustment dropped; refund of ₹78,000 issued.”
Verified Client
CIT(A) appeal allowed under Faceless Appeal Centre
IT Notice Reply
“Section 143(3) addition of ₹62 lakh on unexplained cash deposits during demonetisation. Filed Form 35 with Rule 46A petition; produced sales register, cash book and pre-demonetisation cash trends. CIT(A) deleted addition; Section 220(6) stay of demand obtained pending appeal.”
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Common Questions

IT Notice Reply FAQ — Broadway

Common questions from Broadway clients. Call 9566-068-468 for specific queries.

The High Court's writ jurisdiction under Article 226 of the Constitution is not automatically barred by the existence of a statutory appellate remedy. The Supreme Court in Whirlpool Corporation v. Registrar of Trade Marks and a long line of subsequent authority has held that writ remains available in three classes of cases — breach of fundamental rights, violation of natural justice, and orders without jurisdiction. Tax matters that fit any of these heads — a 148 notice without DIN, a 148A(d) order without supply of material, a 144B assessment without the requested video-conference hearing — are amenable to writ even before the appellate route is exhausted, provided the writ petition is filed promptly.
Section 144C provides a pre-assessment dispute resolution mechanism for 'eligible assessees' — any person in whose case Transfer Pricing adjustment under Section 92CA(3) is proposed, and any foreign company. The AO must pass a draft assessment order and forward it to the assessee. Within 30 days, the assessee may either accept it or file objections to the DRP, which gives directions binding on the AO under Section 144C(10).
Yes — honest advice is the whole point. If IT Notice Reply is not right for your Broadway situation, or can safely wait, we will say so plainly rather than sell you something. That is why much of our work comes through referrals.
Section 270AA provides immunity from penalty under Section 270A and prosecution under Section 276C/276CC where the assessee (i) pays the tax and interest demanded within the period under Section 156, and (ii) does not prefer an appeal against the assessment order. Application in Form 68 must be filed within 1 month from the end of the month in which assessment order is received. Immunity is not available for misreporting (200% category).
Section 143(2) is the gateway notice for regular scrutiny assessment under Section 143(3). It requires the assessee to produce evidence in support of the return. The notice must be served within 3 months from the end of the financial year in which the return was furnished — beyond this period the notice is invalid and any consequent assessment is liable to be quashed.
Yes. Beyond IT Notice Reply, we cover GST, income tax, TDS, company and LLP registrations, digital signatures, audits and finance documentation — so Broadway clients keep all their compliance under one roof. Ask us about anything on 9566-068-468.
No statutory pre-deposit is required to file a CIT(A) appeal under Section 249. However, Section 249(4) bars admission unless tax on returned income is paid (where return was filed) or, where no return was filed, an amount equal to advance tax payable is deposited. For stay of demand pending appeal, CBDT Instruction 1914 (modified by Office Memorandum dated 31-Jul-2017 and 25-Aug-2017) generally requires 20% deposit, relaxable in genuine hardship cases.
Section 264 is revision in favour of the assessee — the Pr.CIT/CIT may, on application or suo motu, revise any order passed by an authority subordinate to him if it is prejudicial to the assessee. Application must be filed within 1 year from the date of communication of the order. Unlike Section 263, no appeal lies against the original order — the assessee chooses between Section 246A appeal and Section 264 revision but cannot pursue both.
Yes. Getting IT Notice Reply right early saves small Broadway businesses from penalties and rework later, and our fixed, modest fees are designed with smaller operators in mind. We will tell you honestly if something is not needed yet.
The base set is — (i) the notice copy with DIN (Document Identification Number — mandatory under CBDT Circular 19/2019), (ii) ITR-V acknowledgement and ITR copy for the AY, (iii) Form 26AS, (iv) AIS and TIS download, (v) computation of total income with workings, (vi) bank statements, (vii) audit report (Form 3CD/3CB) if applicable, and (viii) supporting evidence for the specific issue raised — e.g. capital gains workings, exemption proof, deduction receipts, loan confirmations.
Yes. A first appeal lies to the Commissioner of Income Tax (Appeals) under Section 246A read with Section 250, to be filed in Form 35 within 30 days from the date of service of the demand notice/order. There is no statutory pre-deposit requirement for filing the appeal itself under Section 249. Filing fee ranges from ₹250 to ₹1,000 based on assessed income.
The exact list depends on your case, but we send a short, plain-English checklist the moment you engage us — no jargon. Broadway clients can share documents as phone photos or scans over WhatsApp on 9566-068-468, and we flag immediately if anything is missing.
Best-judgment assessment under Section 144 — the AO completes assessment ex-parte on the material available. Penalty under Section 272A(1)(d) is ₹10,000 for each default of non-compliance with Section 142(1)/142(2A)/143(2). Repeated non-appearance also weakens any subsequent appellate remedy because the appellate authority will require a justification for non-appearance before admitting fresh evidence.
Section 245 empowers the Income Tax Department to set off any refund due to the assessee against any sum remaining payable. The proviso requires prior intimation to the assessee with 21 days to respond before adjustment. CBDT vide Instruction 12/2013 and subsequent directions has reiterated that no adjustment can be made without affording opportunity. Adjustment without pre-intimation is liable to be set aside.
Section 270AA, inserted by the Finance Act, 2016, provides that the assessing authority shall, on receipt of an application in Form 68, grant immunity from penalty under Section 270A and from prosecution under Sections 276C and 276CC, provided two conditions are cumulatively satisfied — the tax and interest payable as per the order have been paid within the period specified in the notice of demand under Section 156, and no appeal is preferred against the assessment order. The application must reach the authority within a single month, reckoned after the close of the month wherein the order is received. Immunity is, however, withheld where the under-reported income is the consequence of misreporting.
File a stay petition with the AO who passed the order, under Section 220(6), supported by appeal acknowledgement, financial hardship affidavit and proof of any deposit made. Per CBDT Office Memorandum dated 31-Jul-2017 (modifying Instruction 1914), 20% of the disputed demand is generally required for stay; the AO has discretion to grant lower deposit in cases of high-pitched assessments or where the issue is covered by jurisdictional High Court ruling.
IT Notice Reply near Broadway:

Across Broadway we look after firms on Broadway Road, Esplanade, Evening Bazaar Road, Netaji Subhash Chandra Bose Road and Rattan Bazaar Road as well as the Audiappa Naicken Street, Errabalu Chetty Street, General Hospital Road and Muthuswamy Road corridors — local IT Notice Reply without the cross-city travel.

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Professional IT Notice Reply in Broadway, Chennai. Call @ 9566-068-468. Offices at Maduravoyal, Nerkundram & Nolambur (upcoming). 15+ years experience, 4.9★ rated.

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