Rated 4.9/5 by 312+ Chennai clientsZero penalty record across all filings24-hour response · WhatsApp-first supportOffices: Maduravoyal, Nerkundram & Nolambur (upcoming)15+ years of expert tax & compliance consulting500+ active clients across 243 Chennai areasRated 4.9/5 by 312+ Chennai clientsZero penalty record across all filings24-hour response · WhatsApp-first supportOffices: Maduravoyal, Nerkundram & Nolambur (upcoming)15+ years of expert tax & compliance consulting500+ active clients across 243 Chennai areas
St Thomas Mount commercial residential mix with airport proximity businesses · IT Notice Reply specialists

Income Tax Notice Reply in St Thomas Mount, Chennai

End-to-end IT Notice Reply for St Thomas Mount commercial residential mix with airport proximity establishments — with same-day acknowledgement delivery

St Thomas Mount hospitality and aviation units around St Thomas Mount Cantonment with WhatsApp document intake and same-day filed-acknowledgement delivery. Call 9566-068-468.

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Quick Answer

What does the firm's internal closure rate on income tax notices actually look like in St Thomas Mount, Chennai?

Across the most recent one hundred and forty-five income tax notices answered at this practice, one hundred and eighteen closed at the e-Proceedings stage without any further questionnaire or escalation. Twenty-two moved into faceless assessment proceedings under Section 144B with a draft assessment order being issued, of which the bulk were either dropped at show-cause stage or settled with a limited addition on the admitted tax. Five travelled the full distance to a Section 246A appeal at the Commissioner of Income Tax (Appeals) level. The dominant reason a 143(1)(a) prima facie adjustment fails to close at e-Proceedings is a missing source document at reply stage, which is why the reconciliation pack is built before the reply letter is drafted. These figures are kept on a running register and shared with the client on intake, rather than as a closing summary.

Transparent Pricing

IT Notice Reply in St Thomas Mount — 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

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

Why FilingPro?

Why St Thomas Mount Clients Choose FilingPro

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

Section 253 ITAT Appeals Taken on Self-Contained Paper Book

Tribunal practice is paper-book practice. The compilation runs to several hundred pages on a contested reassessment — recorded reasons, 148A(b) notice, reply, 148A(d) order, sanction, 148 notice, 142(1) questionnaires, draft assessment order, SCN, reply, assessment order, penalty order, appeal grounds, and CIT(A) order — all indexed and paginated. The synopsis is written so that the bench can grasp the controversy in five minutes; the oral submissions then build only on what the paper book has already established.

Old Regime Versus Section 148A Comparison

The pre-2021 reassessment regime operated through reasons recorded, sanctioning approval and a notice that initiated proceedings without prior hearing. The post-2021 regime imports a quasi-adjudicatory pre-issuance phase under Section 148A. The professional reply leverages the inverted sequence by engaging at the show-cause stage, where the Assessing Officer is statutorily bound to consider the response before the speaking order issues.

Faceless Versus Jurisdictional Assessment Practice

The Section 144B faceless framework severs the traditional taxpayer-officer interface in favour of dynamic allocation across Assessment, Verification, Technical and Review Units. The reply discipline therefore differs from the earlier jurisdictional pattern, with submissions calibrated to the documentary and reasoned-position record rather than to officer rapport, and the video-conference hearing right exercised consistently to preserve natural-justice continuity.

CASS Parameter Discipline Versus Manual Selection

Computer-Assisted Scrutiny Selection has displaced manual selection for the substantial majority of scrutiny cases, with parameters published through internal CBDT directions rather than through statutory rule. The reply confines itself to the parameter that triggered selection, sustaining the limited-scrutiny boundary that Instruction 5 of 2016 enforces, and resists drift into unrelated issues unless fresh approval has been recorded by the Principal Commissioner.

Section 245 Adjustment Response as Recovery Insulation

The twenty-one-day window under Section 245 is treated as a discrete procedural opportunity to record the demand status independently of the formal recovery track under Sections 220 to 222. Reply options of demand correct, partially incorrect or disagreed are exercised on documentary support such as appellate acknowledgement, stay order or rectification application, preventing refund-set-off becoming an inadvertent recovery substitute.

Three- and Ten-Year Limitation Mapping for Reassessment

Section 149 applies a three-year general limit and a ten-year extended limit conditioned on books, documents or evidence revealing escaped income above fifty lakh rupees represented in asset, expenditure or entry. Mapping each Section 148 notice against the threshold, the surviving Ashish Agarwal and Rajeev Bansal timeline and the specified-authority sanction under Section 151 produces the limitation-defence position that frames the reply.

Key Benefits

What St Thomas Mount Clients Get

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

Section 154 Rectification — Faster Remedy
For mistake apparent from record — TDS credit not given, Section 87A rebate missed, arithmetical error, AIS mismatch — Section 154 rectification is filed online for a faster, fee-free remedy than appeal.
Statutory Window Charted
The relevant period of limitation is identified on day one — thirty days for the prima-facie adjustment letter, the seven-to-thirty-day window for the show-cause stage, and the twenty-one-day period for the refund-adjustment intimation under Section 245.
Issue-Wise Submission Drafted
Each adjustment proposed by the prescribed authority is dealt with as a separate paragraph, with the legal foundation, the computation under contest and the documentary evidence appended in the order in which they are referred to in the body of the reply.
Authority Citations Provided
The reply incorporates citations from the jurisdictional High Court, the Tribunal benches having appellate authority over the assessee's territorial circle, and binding Supreme Court rulings — including the Ashish Agarwal and Rajeev Bansal decisions where the reopening regime is at issue.
Reconciliation Schedule Annexed
A schedule comparing the return as filed, the entries appearing in the Annual Information Statement, the Tax Information Summary and Form 26AS is annexed. Each variance is either explained, contested through the feedback module, or surrendered with consequential payment.
Computation Sheet Reconstructed
A head-wise total income computation under the five heads enumerated in Section 14 is reconstructed from primary evidence — salary statement, rent receipt, business book extracts, capital-gain schedule, and the residual head — to ensure internal consistency before filing.
Comparison

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

Why this matters here — In St Thomas Mount, the business activity radiating outward from St Thomas Mount Cantonment and nearby commercial pockets; with quick access via St Thomas Mount Metro and feeder routes connecting St Thomas Mount to the rest of Chennai.

AspectSection 148 Old Regime (pre 01-Apr-2021)Section 148A New Regime (post 01-Apr-2021)
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
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
Documents Required

Documents for IT Notice Reply

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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 St Thomas Mount, the cluster of hospitality, aviation, logistics businesses that defines St Thomas Mount'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 St Thomas Mount: For St Thomas Mount engagements specifically — for St Thomas Mount IT-services firms managing export-LUT cycles alongside payroll and TDS.

Forms Library

Forms used in this engagement

Notice u/s 143(2)Notice for scrutiny assessment

Notice issued by Assessing Officer or prescribed authority requiring the assessee to attend the office or produce evidence in support of the return; selection follows CASS criteria notified by CBDT for the assessment year

Within three months from end of financial year of return filing — Section 143(2) proviso Jurisdictional Assessing Officer / National Faceless Assessment Centre
Notice u/s 142(1)Inquiry notice before assessment

Notice calling for return where none has been furnished, production of accounts and documents, or any information on points considered necessary for assessment; non-compliance attracts Section 271(1)(b) penalty

Any time before completion of assessment; reply window typically fifteen days Assessing Officer / Faceless Assessment Unit
Notice u/s 148A(b)Show-cause notice for issue of Section 148 notice

Show-cause notice provided to assessee under Section 148A(b) along with the information suggesting escapement of income, seeking the assessee's reply before the officer passes the Section 148A(d) order

Not less than seven days and not more than thirty days from service for reply Jurisdictional Assessing Officer with approval of Specified Authority
Order u/s 148A(d)Order deciding fitness for Section 148 notice

Speaking order recording satisfaction that it is or is not a fit case to issue a Section 148 notice; precedes the Section 148 reassessment notice and is the document on which validity of subsequent proceedings rests

Within one month from end of month in which Section 148A(b) reply is received Jurisdictional Assessing Officer with approval of Specified Authority
Notice u/s 148Reassessment notice

Notice requiring the assessee to furnish a return of income for the relevant assessment year within the period specified in the notice, where the Assessing Officer has reason to believe income has escaped assessment

Within limitation under Section 149 — three years ordinary or ten years in escapement above ₹50 lakh cases Jurisdictional Assessing Officer / Faceless Assessment Unit
Notice u/s 154Rectification — proposed amendment of order

Communication of proposed amendment to an order or intimation where mistake apparent from record is noticed; the assessee is required to be heard before any amendment which has the effect of enhancing assessment or reducing refund is made

Within four years from end of financial year of original order Issuing income-tax authority — AO, CIT(A), or CPC
Notice u/s 245Prior intimation of set-off of refund against demand

Intimation proposing adjustment of refund determined as due against outstanding demand, mandated by the Hon'ble Delhi High Court ruling in Court On Its Own Motion v UoI; requires speaking order before adjustment

Thirty days for the assessee to respond before set-off is given effect Centralised Processing Centre / Jurisdictional AO
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

IT Notice Reply in St Thomas Mount, Chennai 600016

St Thomas Mount (PIN 600016) falls under the Saidapet Division of the Chennai South, the jurisdiction that handles statutory matters for businesses at this PIN. Businesses registered in St Thomas Mount share the Chennai South jurisdiction, and their statutory matters route through the same Saidapet Division each time. Because PIN 600016 sits inside the Chennai South jurisdiction, the handling office for St Thomas Mount stays consistent across years, which matters when filings or approvals span cycles. For IT Notice Reply at PIN 600016, understanding the Saidapet Division's documentation norms removes most of the friction from the process.

Document pickup near Mount Railway Station is a same-hour errand for our St Thomas Mount engagements rather than the half-day a typical Chennai client expects. Freight and foot traffic from the St Thomas Mount Metro hub pull steady daily commerce through St Thomas Mount, so there is rarely a quiet filing month in this commercial residential mix with airport proximity pocket. Most commerce in St Thomas Mount — invoices, expenses, purchases and statutory records — eventually surfaces in the IT Notice Reply working file we maintain for clients here. St Thomas Mount sustains a high flow of commerce for a commercial residential mix with airport proximity locality, and that flow is the raw material for the IT Notice Reply files we close here.

For a hospitality business in St Thomas Mount, the IT Notice Reply scope is rarely generic; we tailor the checklist to how that sector actually transacts. IT Notice Reply for hospitality businesses in St Thomas Mount hinges on getting the sector's recurring entries right the first time. We have closed enough IT Notice Reply files for hospitality firms near St Thomas Mount to know where the department usually probes. Sector concentration matters: when St Thomas Mount leans toward hospitality, the IT Notice Reply risks cluster around the same few line items each cycle.

Turnaround for St Thomas Mount IT Notice Reply is deterministic — fixed fee, a scoped timeline, and a same-business-day acknowledgement once filed. The St Thomas Mount IT Notice Reply workflow is documented end-to-end: WhatsApp document intake, a working file, qualified review, and a filed acknowledgement back to you. Fixed-fee scoping means a St Thomas Mount business knows the IT Notice Reply cost up front, with no surprise additions mid-engagement. Working papers for St Thomas Mount IT Notice Reply engagements stay archived and retrievable, which makes any later notice or query straightforward to answer.

From the same St Thomas Mount team we also serve Guindy and other nearby localities without re-onboarding clients. A client relocating between St Thomas Mount and Guindy keeps the same IT Notice Reply file and the same team. Proximity to Guindy means a St Thomas Mount engagement can extend across the locality cluster with no change in cadence. Serving St Thomas Mount and Guindy from one team keeps IT Notice Reply turnaround identical across the cluster.

Patterns we track for St Thomas Mount include logistics documentation gaps, timing mismatches, and the questions the Saidapet Division tends to raise. Over several cycles in St Thomas Mount, the recurring IT Notice Reply issues cluster around a predictable short list we screen for early. The longer we serve St Thomas Mount, the more precisely we predict where a IT Notice Reply file needs attention. Because we work repeatedly across St Thomas Mount, we can benchmark a new client's IT Notice Reply position against the locality norm.

For a new business incorporating in St Thomas Mount or shifting its principal place of business here, IT Notice Reply setup is one of the first things to get right. A startup setting up near Chennai Airport in St Thomas Mount gets a IT Notice Reply foundation built for the Saidapet Division from day one. When a Nandambakkam business expands into St Thomas Mount, we extend its IT Notice Reply setup to PIN 600016 without disruption. We onboard new St Thomas Mount 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 St Thomas Mount — Complete Guide

Sub-section (1) of Section 143 contemplates a centralised processing exercise. The proposed prima-facie adjustment letter under clause (a) of that sub-section is the precursor; an intimation thereafter quantifies the demand or refund. The textbook position is that this is not an assessment but a summary computation, and the response must address the proposed adjustment within the prescribed window.

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Key Facts — IT Notice Reply in St Thomas Mount
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 St Thomas Mount
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 a Section 156 demand verification step before payment?

Match the demand amount against the assessment-order computation, verify any TDS and advance-tax credits, check Section 234A/B/C interest computation, confirm any already-paid challans appear in AS-26, and confirm the demand is not stayed by an appeal or rectification pending.

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 St Thomas Mount clients want to know before signing: For St Thomas Mount engagements specifically — on the Guindy-Alandur corridor that passes through St Thomas Mount.

Expert Guide

A complete walkthrough — Income Tax Notice Reply

Reading this guide locally — In St Thomas Mount, around the St Thomas Mount Cantonment catchment of St Thomas Mount.

What is an income tax notice and what triggers it

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.

Common triggers from CASS and AIS-based selection

The Computer-Assisted Scrutiny Selection module operated by the Directorate of Income Tax (Systems) selects returns for scrutiny under Section 143(2) using statistical risk parameters drawing on the Annual Information Statement, Form 26AS aggregates, Goods and Services Tax Network data, depository feeds, and registrar-of-companies disclosures. Common triggers include mismatch between GSTR-3B outward supplies and ITR turnover, high-value bank deposits relative to declared income, foreign remittances under Liberalised Remittance Scheme exceeding declared sources, large refund claims, and cross-tax-base inconsistencies. The Annual Information Statement framework introduced by CBDT Circular 8/2021 consolidates third-party reports into a single feed that the assessee can review pre-filing, while the corresponding Taxpayer Information Summary provides an aggregated overview. Where pre-filing review identifies AIS errors, the assessee can submit feedback through the e-filing portal to mark entries as duplicate, incorrect, or relating to another person, with the corrected AIS forming the basis for subsequent scrutiny selection.

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.

Section 142(1) inquiry mechanism

Section 142(2A) special audit and procedural safeguards

Section 142(2A) empowers the Assessing Officer, with the prior approval of the Principal Commissioner or Commissioner, to direct the assessee to get the accounts audited by an accountant nominated by the Principal Commissioner. The conditions are that the accounts are complex or have multiple transactions, that the volume is such, or that the doubt over correctness of the accounts requires special audit. The Section 142(2C) limitation provides that the audit must be completed within a period not exceeding one hundred eighty days from the date of receipt of the direction. The Sahara India Mass Communication Supreme Court ruling has clarified that the satisfaction recorded for invoking Section 142(2A) must be objectively justified, with the assessee entitled to challenge the direction through Article 226 writ before the Madras High Court where the satisfaction is patently unreasonable. The audit cost is borne by the Central Government under Section 142(2D), removing the cost-shifting argument from the consideration set.

Scope of inquiry and information-gathering authority

Section 142(1) of the Income-tax Act provides the Assessing Officer with authority to call for information from any person, including the assessee, to enable assessment. The provision contains three clauses — Section 142(1)(i) requires the assessee to file a return where one has not been filed, Section 142(1)(ii) requires the assessee to produce accounts and documents specified in the notice, and Section 142(1)(iii) requires the assessee to furnish information on matters specified by the Assessing Officer. The Section 142(2) supplemental power authorises the Assessing Officer to make such inquiry as considered necessary for the purpose of obtaining full information in respect of the income or loss of any person. The Section 142(2A) special audit provision allows the Assessing Officer, with the prior approval of the Principal Commissioner or Commissioner, to direct the assessee to get the accounts audited by a chartered accountant nominated by the Principal Commissioner. The framework is investigatory rather than adjudicatory at this stage.

Compliance windows and faceless processing

The Section 142(1) notice specifies the date by which the response is to be furnished, with windows typically ranging from fifteen to thirty days depending on the volume and complexity of information sought. Under the Faceless Assessment Scheme codified in Section 144B, the notice is issued by the National Faceless Assessment Centre and the response is submitted through the e-Proceedings module on the e-filing portal. Extensions can be sought through the same portal with a reasoned application, with the Assessing Officer empowered to grant additional time where bona fide reasons exist. Non-compliance with Section 142(1) attracts the Section 271(1)(b) penalty of ten thousand rupees for each default and may trigger Section 144 best-judgment assessment where the Assessing Officer proceeds without the assessee's input. The faceless framework eliminates direct interaction with the Assessing Officer, with all communication routed through the portal.

Section 143(2) scrutiny assessment

Personal hearing rights and natural justice

The right to personal hearing in scrutiny proceedings has been the subject of significant jurisprudence. Section 144B(7) provides for personal hearing through video conferencing in circumstances prescribed by the Board, with the Sanjay Aggarwal Delhi HC ruling and the Bharat Aluminium Calcutta HC ruling holding that the request for personal hearing in defined circumstances must be granted as a matter of natural justice where adverse adjustments are contemplated. The Kranti Associates Supreme Court ruling on reasoned decision-making applies broadly to require the Assessing Officer to engage with each material submission made by the assessee in the response, with non-engagement vitiating the order. The combination of these rulings makes the personal-hearing request a strategic step in scrutiny where the assessee anticipates adverse adjustments, with the request to be made through the e-Proceedings portal in the prescribed form.

Response strategy and the GKN Driveshafts framework

The GKN Driveshafts Supreme Court ruling, although decided in the Section 148 reassessment context, has been extended by High Courts to the broader scrutiny framework — the assessee is entitled to seek the reasons recorded for the adverse position before responding substantively, and the Assessing Officer is required to dispose of the assessee's objections through a speaking order before proceeding. In Section 143(2) scrutiny, this translates to a structured response strategy — first, an information request seeking the basis for the proposed adjustment; second, a substantive response with documentary substantiation addressing each proposed adjustment line; third, where applicable, a personal-hearing request through video conferencing; fourth, post-order, the Section 246A appeal route to the Commissioner of Income Tax (Appeals) within thirty days. The Kranti Associates principle on reasoned decision-making reinforces the speaking-order requirement.

Selection mechanism and statutory framework

Section 143(2) authorises the Assessing Officer to serve a notice on the assessee selected for scrutiny assessment, requiring the assessee to attend or produce evidence on which the assessee relies in support of the return. The selection is through Computer-Assisted Scrutiny Selection or through manual selection under Section 119 instructions, with the scope of scrutiny limited to either the issues notified in the notice (limited scrutiny) or to all issues (complete scrutiny). The CBDT Instruction 5/2017 and subsequent Circulars prescribe the parameters and percentages for scrutiny selection across CASS cycles, with limited scrutiny being the predominant mode for routine selection. The notice must be served within three months from the end of the financial year in which the return was furnished under the post-2021 amendment to Section 143(2), with the earlier six-month window curtailed by the Finance Act 2021. Non-service within the statutory window is fatal to the scrutiny assessment as held in ACIT v Hotel Blue Moon (SC, 2010).

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.

What St Thomas Mount clients usually ask next: For St Thomas Mount engagements specifically — for St Thomas Mount IT-services firms managing export-LUT cycles alongside payroll and TDS.

Glossary

Plain-English glossary for this service

Pre-deposit of twenty per cent

Pre-deposit of twenty per cent refers to the threshold prescribed by CBDT Office Memorandum F. No. 404/72/93-ITCC dated 29 February 2016, as modified by OM dated 31 July 2017 — twenty per cent of the disputed demand to be deposited ordinarily for the Assessing Officer to grant stay under Section 220(6) during pendency of Section 246A appeal.

Recovery under Section 222

Recovery under Section 222 is the recovery of arrears under the Second Schedule procedure — by attachment and sale of movable and immovable property of the assessee, by appointment of a receiver, or by arrest and detention. Triggered after expiry of Section 220(1) demand window and where stay has not been granted.

Tax Recovery Officer

Tax Recovery Officer is the officer designated under Section 223 for recovery of arrears from a defaulter. The TRO operates under the Second Schedule procedure — issue of certificate, attachment and sale of property, appointment of receiver. Distinct from the Assessing Officer; recovery proceedings cease only with payment or stay.

Section 226(3) garnishee notice

Section 226(3) garnishee notice is the recovery notice issued to any person from whom money is due or may become due to the assessee — typically banks where the assessee holds accounts, debtors of a business, employers in TDS-deduction scenarios. The notice operates as an attachment and the garnishee is to pay over to the Department.

e-Proceedings

e-Proceedings is the dedicated tab on the Income Tax e-portal through which all notices, queries, responses and orders flow under the faceless framework. The assessee uploads replies as PDF along with annexures. Notice-wise communication thread preserves the audit trail of submissions for any subsequent appeal.

Personal hearing through video conferencing

Personal hearing through video conferencing is the mode of hearing under Section 144B(7) read with the Faceless Assessment Scheme — afforded on a written request by the assessee in cases where the proposed addition is adverse. The hearing is conducted by the assessment unit officer through the e-portal video facility.

Assessment unit

Assessment unit is the operational unit under the National Faceless Assessment Centre that examines the return and the assessee's submissions and drafts the assessment order. Dynamic allocation across India ensures arm's-length adjudication. The draft order is reviewed by a separate review unit before finalisation in significant-addition cases.

Verification unit

Verification unit is the operational unit under the National Faceless Assessment Centre that conducts third-party verifications during scrutiny — calls for information from banks, vendors, parties to transactions under Section 133(6). The verification report flows back to the assessment unit for incorporation in the assessment.

Technical unit

Technical unit is the operational unit under the National Faceless Assessment Centre that provides legal, valuation, transfer pricing or accounting opinions to the assessment unit on technical issues. Engaged where the assessment turns on a specialised question; the opinion guides but does not bind the assessment unit.

Review unit

Review unit is the operational unit under the National Faceless Assessment Centre that examines the draft assessment order, particularly in cases of significant proposed additions or where the assessment unit has rejected the assessee's claims. The review unit may suggest variations before the order is finalised.

Standard Operating Procedure for assessment

Standard Operating Procedure for assessment is the operational guideline issued by CBDT for conduct of scrutiny — defining timelines for issue of questionnaire, evidence-collection windows, restrictions on remand of issues, requirements for draft order in significant-addition cases. The SOP supplements the statutory framework with administrative discipline.

Survey under Section 133A

Survey under Section 133A is the inspection of business premises during business hours for verification of books, stocks, cash and documents. Distinct from search under Section 132 — no seizure of books or documents (only impounding), no examination of residence, recording of statements without administration of oath.

Cost of Non-Compliance

Real-world penalty exposure

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

ScenarioBase taxInterestPenaltyTotal
Section 234F late-filing fee for return filed on 15-Sep-2024 (after 31-Jul-2024 due date)Not applicable (fee not tax)Not applicable₹5,000 (Section 234F where total income exceeds ₹5 lakh)₹5,000
Section 271AAB undisclosed-income penalty at 10 per cent (immunity-conditions satisfied) on ₹20 lakh admitted during Section 132 search₹6,24,000 (₹20,00,000 × 31.2 per cent)₹74,880 (Section 234B 1 per cent × 12 months)₹2,00,000 (Section 271AAB(1A)(a) at 10 per cent of undisclosed income)₹8,98,880
Section 271AAB at 30 per cent (immunity-conditions NOT satisfied) on ₹15 lakh undisclosed income found in Section 132 search₹4,68,000 (₹15,00,000 × 31.2 per cent)₹56,160 (Section 234B 1 per cent × 12 months)₹4,50,000 (Section 271AAB at 30 per cent of undisclosed income)₹9,74,160
Section 272A(1)(d) penalty for four Section 142(1) compliance defaults during scrutinyNot applicableNot applicable₹40,000 (₹10,000 × 4 defaults)₹40,000
Section 271C TDS non-deduction penalty on professional fees of ₹6 lakh where Section 194J TDS was not deducted₹60,000 (₹6,00,000 × 10 per cent TDS) recoverable from deductor₹16,200 (Section 201(1A) at 1 per cent per month from deduction-due date plus 1.5 per cent from deposit-due date)₹60,000 (Section 271C at amount equal to TDS that should have been deducted)₹1,36,200
Section 271(1)(c) legacy concealment penalty on AY 2017-18 addition of ₹10 lakh sustained at ITAT₹3,12,000 (₹10,00,000 × 31.2 per cent)₹2,99,520 (Section 220(2) 1 per cent × 96 months)₹3,12,000 (Section 271(1)(c) at 100 per cent of tax sought to be evaded)₹9,23,520

How St Thomas Mount businesses typically avoid these: For St Thomas Mount engagements specifically — the business activity radiating outward from St Thomas Mount Cantonment and nearby commercial pockets; for St Thomas Mount IT-services firms managing export-LUT cycles alongside payroll and TDS.

By Industry

Industry-specific patterns in St Thomas Mount

How the local trade mix shapes this — In St Thomas Mount, the business activity radiating outward from St Thomas Mount Cantonment 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.
Logistics
Common issue: Goods transport operators owning ten or fewer carriages under Section 44AE often receive Section 143(1)(a) intimations where the deemed profit declared in Schedule BP does not match the per-ton-per-month computation expected by the CPC matching algorithm for heavy goods vehicles versus other classes. The intimation cites apparent inconsistency between the vehicle-class declaration and the deemed-profit aggregate.
How we handle it: Respond within thirty days enclosing the vehicle-wise register capturing gross vehicle weight, registration date, and ownership months during the previous year; reconcile each vehicle to the applicable Section 44AE rate (one thousand rupees per ton per month for heavy goods vehicles, seven thousand five hundred rupees per month otherwise); produce the Form 3CD clause 13 audit disclosure where applicable; pursue Section 154 rectification if the prima facie adjustment is incorrect.
Residential
Common issue: Salaried individuals owning a self-occupied residential property and a let-out second property frequently receive Section 143(1)(a) intimations proposing disallowance of the Section 24(b) interest deduction in excess of two lakh rupees in aggregate. The CPC adjustment mechanism does not always bifurcate the cap (which applies only to self-occupied property) from the let-out property's full interest entitlement under the main provision of Section 24(b).
How we handle it: Respond within thirty days enclosing the property-wise designation under Section 23(4) (self-occupied versus let-out); produce the interest certificate from the lender for each property separately; reconcile the Schedule HP entries in ITR-2 or ITR-3 with the interest claim; demonstrate that the Section 71(3A) two-lakh cap on house-property loss against other heads has been applied correctly with the balance carried forward under Section 71B.
Case Studies

Anonymised engagements we have handled

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

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.
Section 272A(1)(d)Hospitality

Penalty under Section 272A(1)(d) for Section 142(1) non-compliance

Issue: A hotel proprietor received a Section 272A(1)(d) penalty notice of ₹40,000 for failure to comply with four Section 142(1) information notices during a scrutiny assessment. The penalty was being levied at ₹10,000 per default. The proprietor had in fact uploaded responses on the e-portal but the AO's draft order did not record receipt.
Approach: Filed a reply to the Section 272A show-cause annexing the e-portal acknowledgement screens, time-stamped uploads and a sworn statement that compliance had been effected within the prescribed windows. Argued that 'failure to comply' under Section 272A(1)(d) requires actual non-compliance, not a portal-side display defect at the AO's end. Sought complete dropping of the penalty.
Outcome: AO accepted the e-portal evidence; the Section 272A(1)(d) penalty was dropped entirely; no penalty was levied; the underlying scrutiny assessment closed at returned income; client's SOP added e-portal acknowledgement preservation as a standing practice.
Section 271(1)(c) legacyRetail

Section 271(1)(c) penalty on legacy assessment year vacated

Issue: A retail-pharmacy proprietor received a Section 271(1)(c) concealment penalty order for AY 2017-18 of ₹6.4 lakh — the order pertained to additions made in a Section 143(3) assessment that had been substantially deleted on appeal before the CIT(A). The penalty order had nevertheless been passed mechanically on the original additions without taking the appellate deletion into account.
Approach: Filed an appeal under Section 246A challenging the penalty on two grounds — (a) the underlying additions had been deleted, so the penalty foundation was gone, and (b) the penalty notice did not strike out the inapplicable limb of 'concealment' versus 'furnishing of inaccurate particulars', a defect held to be fatal in Manjunatha Cotton & Ginning Factory (Karnataka HC) and accepted by the Supreme Court in Dilip N Shroff.
Outcome: CIT(A) vacated the Section 271(1)(c) penalty in full; both grounds were accepted; refund of the pre-deposit was released with Section 244A interest; the firm's SOP for penalty challenges now insists on inspecting the limb-striking question as the first screening point.

Why these St Thomas Mount engagements look the way they do: For St Thomas Mount engagements specifically — the business activity radiating outward from St Thomas Mount Cantonment and nearby commercial pockets; for St Thomas Mount IT-services firms managing export-LUT cycles alongside payroll and TDS.

Client Reviews

What St Thomas Mount 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 — St Thomas Mount

Common questions from St Thomas Mount clients. Call 9566-068-468 for specific queries.

Across the most recent one hundred and forty-five income tax notices answered at this practice, one hundred and eighteen closed at the e-Proceedings stage without any further questionnaire or escalation. Twenty-two moved into faceless assessment proceedings under Section 144B with a draft assessment order being issued, of which the bulk were either dropped at show-cause stage or settled with a limited addition on the admitted tax. Five travelled the full distance to a Section 246A appeal at the Commissioner of Income Tax (Appeals) level. The dominant reason a 143(1)(a) prima facie adjustment fails to close at e-Proceedings is a missing source document at reply stage, which is why the reconciliation pack is built before the reply letter is drafted. These figures are kept on a running register and shared with the client on intake, rather than as a closing summary.
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.
Yes — 600016 (St Thomas Mount) is well within our service area. We handle IT Notice Reply for this PIN and the surrounding 600xxx localities routinely, with the full process available online or in person.
Section 143(1)(a) gives the taxpayer 30 days from the date of intimation to respond on the e-filing portal under 'e-Proceedings'. Each proposed adjustment must be accepted or contested with supporting computation, Form 26AS reconciliation, AIS feedback, deduction proof and any audit report annexure. If no reply is filed within 30 days, the adjustment is finalised and the consequential demand or reduced refund stands.
For searches initiated on or after 01-Apr-2021, Finance Act 2021 abolished the earlier Section 153A/153C block-assessment regime and brought search cases also within the Section 147/148/148A framework, with the 10-year extended limit applying where escaped income represented in asset/expenditure/entry exceeds ₹50 lakh. Sanction of specified authority under Section 151 is mandatory.
Yes. Beyond IT Notice Reply, we cover GST, income tax, TDS, company and LLP registrations, digital signatures, audits and finance documentation — so St Thomas Mount clients keep all their compliance under one roof. Ask us about anything on 9566-068-468.
NFAC sends a Section 143(2) notice through the e-filing portal. The Assessment Unit issues Section 142(1) questionnaires. Replies are uploaded online — no physical visit. Where addition is proposed, a draft assessment order with show-cause is issued. The assessee can request personal hearing by video conference, which must be granted under Section 144B(6)(viii) — denial vitiates the order on natural justice grounds.
In Union of India v. Ashish Agarwal (Civil Appeal 3005/2022, decided 04-May-2022), the Supreme Court held that Section 148 notices issued under the old regime between 01-Apr-2021 and 30-Jun-2021 (after the new regime had come into force) shall be deemed to be Section 148A(b) show-cause notices under the new regime. The Court invoked Article 142 to balance revenue and assessee interests for over 90,000 pending notices.
Our work is led by Ravivarman R, a tax practitioner with 15+ years and 500+ engagements, backed by specialists in compliance and GST. We base every IT Notice Reply recommendation on current law and your actual facts — not generic templates — and we are happy to explain the reasoning.
Section 154 allows rectification of a 'mistake apparent from the record' in any order — including 143(1) intimation, 143(3) assessment, 144 ex-parte order, or 200A TDS processing. The application can be filed online within 4 years from the end of the financial year in which the order was passed. Mistakes covered include arithmetical error, wrong tax credit (Form 26AS not given), TDS/TCS not allowed, and incorrect carry-forward of loss.
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, we regularly take over part-completed IT Notice Reply work. Share what has been done so far on WhatsApp 9566-068-468 and we will review it, point out anything that needs correcting, and continue from where you are.
On receipt of the Section 245 intimation, log in to e-filing portal, navigate to 'Pending Actions > Outstanding Demand', and respond within 21 days choosing 'Demand is correct', 'Demand is partially incorrect' or 'Disagree with demand'. For each disputed demand, upload assessment order, challan, rectification application or appeal pendency proof. Silence is treated as agreement and refund is adjusted.
Section 144B introduced by Finance Act 2021 (replacing the earlier scheme notified in 2020) mandates that all assessments under Section 143(3) and Section 144 are conducted in a faceless manner through the National Faceless Assessment Centre (NFAC). The flow involves NFAC issuing notices, the Assessment Unit drafting, the Verification Unit verifying, the Technical Unit advising, the Review Unit reviewing, and a draft assessment order communicated to the assessee with a Show-Cause Notice before any addition. Personal hearing is by video conference only.
Yes. Section 260A provides appeal to the High Court within 120 days from the date of receipt of the ITAT order, but only on a 'substantial question of law'. Pure findings of fact by the Tribunal are not appealable. The High Court formulates the question, hears both sides and passes a reasoned judgment under Section 260A(4)/(5).
Section 270A (replacing Section 271(1)(c) for AY 2017-18 onwards) levies penalty of 50% of tax on under-reported income and 200% of tax on misreported income. Misreporting includes misrepresentation/suppression of facts, false entries, claim of expenditure not substantiated, failure to record investment in books, etc. Immunity is available under Section 270AA where tax and interest are paid and no appeal is filed.
IT Notice Reply near St Thomas Mount:

Across St Thomas Mount we look after firms on College Road, Krishnasamy Street, Lake View Road, Grand Southern Trunk Road and Inner Ring Road (Southern Sector) as well as the Mount - Medavakkam Road, St Thomas Mount Subway, Station Road and Thillaiganga Nagar Subway corridors — local IT Notice Reply without the cross-city travel.

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