The corresponding sections of the Income-tax Act, 2025 (formerly Section 143(3), Section 144B, Section 147/148 & Section 246A of Income Tax Act, 1961)

Faceless Assessments & Appeals Representation

Statutory legal defense and representation before the National Faceless Assessment Centre (NaFAC), reassessment proceedings (Section 148 of the 1961 Act and the corresponding sections of the 2025 Act), appellate litigation before CIT(Appeals), and Income Tax Appellate Tribunal (ITAT) benches.

CA Due Diligence

Official Portal Filing

State Stamp Advisory

Faceless Assessments & Appeals Representation Statutory Advisory

Statutory Filing

MCA & Tax Practice

Relevant RegulatorCBDT & NaFAC, Ministry of Finance, Govt of India

Income Tax e-Filing Official Portal

The official Government of India portal for e-Proceedings, responding to statutory notices, submitting written paper books, requesting VC hearings, and e-filing Form 35 appeals before CIT(Appeals).

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STATUTORY OVERVIEW

Faceless Assessments, Reassessment & Appellate Representation

Direct tax scrutiny, reassessment, and appellate defense operate through an automated, jurisdiction-free digital ecosystem under the Income-tax Act, 2025 alongside transitional provisions governing ongoing matters under the Income-tax Act, 1961. With automated case allocation through the National Faceless Assessment Centre (NaFAC), written documentation, evidentiary substantiation, and precise legal drafting have become the foundation of effective tax defense. Our practice provides technical representation, drafting structured responses to statutory notices, managing reassessment proceedings under Section 148 (1961 Act), and arguing appeals before appellate authorities in strict conformity with ICAI standards.

Statutory & Practice Summary • At-A-Glance

ICAI UDIN Authentication Mandate

Governing Framework

The corresponding sections of the Income-tax Act, 2025 (formerly Section 143(3), Section 144B, Section 147/148 & Section 246A of Income Tax Act, 1961)

Regulatory Authority

National Faceless Assessment Centre (NaFAC) & Central Board of Direct Taxes (CBDT), Ministry of Finance, Govt of India

Professional Assurance

Chartered Accountants Attestation under ICAI Standards & Code of Ethics

DOCUMENTATION MATRIX

Mandatory Documents Checklist

Self-attested scanned copies required

1. Promoters / Partners / Directors KYC

✓Copy of the Statutory Notice issued u/s 143(2) / 142(1) or Section 148 (1961 Act), or the corresponding sections of the 2025 Act
✓Digital Signature Certificate (DSC Class 3) of the Assessee / Authorized Signatory
✓Power of Attorney / Form 35 / Letter of Authority authorizing Chartered Accountant representation
✓PAN Card, Aadhaar Card, and incorporation documents of the assessee entity

2. Registered Office & Premises Proof

✓Latest e-Filing Portal Profile verification and active registered communication email/mobile
✓Proof of registered office address corresponding to jurisdictional tax communications

3. Specific Statutory Declarations & Enclosures

•Filed ITR Acknowledgments and computation of total income for the relevant assessment year(s)
•Complete Audited Financial Statements, Tax Audit Reports in Form 3CD, and Notes to Accounts
•Point-by-point paper book documentation, bank statement reconciliations, and third-party confirmations
•Substantiating contracts, invoices, confirmation of accounts, and ledger extracts rebutting additions
•Detailed factual and legal rebuttal submissions citing binding Supreme Court / High Court precedents

PROCEDURAL ROADMAP

Step-by-Step Filing & Approval Process

Structured execution roadmap managed by our Chartered Accountants from pre-filing due diligence to certificate allotment.

01Days 1 - 3

Notice Analysis & Jurisdictional Verification

Examining notice validity under Section 143(2) (1961 Act) or Section 148 (1961 Act), checking limitation timelines, and identifying issues framed by NaFAC.

02Days 4 - 10

Evidentiary Compilation & Ledger Sync

Collating source documentation, bank reconciliations, creditor confirmations, and preparing exhaustive evidentiary paper books aligned with ICAI defense standards.

03Days 11 - 18

Electronic Submission & Video Conference

Submitting structured electronic replies on the e-filing portal, seeking Video Conferencing (VC) hearings before the Assessment Unit, and recording oral arguments.

04Post-Assessment

Assessment Order Review & Appellate Relief

Reviewing final assessment order, rectifying apparent mistakes u/s 154, or drafting Form 35 appeal before Commissioner (Appeals) with stay of demand u/s 220(6).

Scrutiny Assessments & Faceless Assessment Scheme

When an Income Tax Return is selected for scrutiny under the corresponding section of the Income-tax Act, 2025 (formerly Section 143(2) of the Income-tax Act, 1961), taxpayers receive detailed inquiry questionnaires under Section 142(1) (1961 Act). Every response submitted through the e-filing portal must be supported by comprehensive accounting reconciliations, documentary evidence, and statutory arguments to prevent arbitrary additions.

Faceless Scheme (formerly Section 144B)

Digital Architecture

Seamless navigation across Assessment Units (AU), Verification Units (VU), and Review Units (RU) within the automated allocation framework.

Stay of Demand (formerly Section 220(6))

Demand Management

Drafting applications before Assessing Officers and appellate authorities for stay of outstanding tax demands upon payment of statutory deposits.

Handling Limited and Complete Scrutiny notices under statutory provisions (formerly Section 143(2) of the Income-tax Act, 1961) with structured, point-by-point replies

Reconciliation of large cash deposits, property acquisitions, share capital infusions, and SFT data with declared income

Drafting comprehensive replies to Show Cause Notices (SCN) issued with draft assessment orders proposing additions

Availing statutory rights to Video Conferencing (VC) hearings before NaFAC assessment units under faceless assessment rules (formerly Section 144B)

Reassessment Proceedings (formerly Section 148 & 148A)

Reassessment proceedings under the corresponding section of the Income-tax Act, 2025 (formerly Sections 147, 148, and 148A of the Income-tax Act, 1961) require strict adherence to statutory prerequisites. Before issuing a reassessment notice, tax authorities must furnish information suggesting income escaping assessment and issue a show-cause notice (formerly Section 148A(b)). Taxpayers have the statutory right to challenge the validity of proceedings on grounds of jurisdictional errors, limitation periods, or lack of nexus.

Drafting objections to show-cause notices (formerly Section 148A(b) of the Income-tax Act, 1961) demonstrating that income has not escaped assessment

Challenging reassessment orders passed under statutory inquiry provisions (formerly Section 148A(d)) on procedural and substantive legal grounds

Verifying adherence to statutory limitation periods (3 years for general cases; up to 5 years where escaped income exceeds ₹50 Lakhs)

Compiling historical ledgers, bank statements, and transaction vouchers to rebut allegations of unrecorded transactions

Appellate Proceedings: CIT(Appeals) & ITAT Representation

Where assessment orders result in unjustified additions, disallowances, or penalty levies under statutory provisions (formerly Section 270A of the Income-tax Act, 1961), taxpayers can exercise their statutory right of appeal before the Commissioner of Income Tax (Appeals) [Faceless Appeal Centre] and subsequently before the Income Tax Appellate Tribunal (ITAT). Effective appellate advocacy demands meticulous formulation of Grounds of Appeal and comprehensive Paper Book preparation.

First Appeal: CIT(Appeals)

Formerly Section 246A

Drafting comprehensive Statement of Facts, legal Grounds of Appeal in Form 35, and written submissions citing binding Supreme Court and High Court precedents.

Second Appeal: ITAT Benches

Formerly Section 253

Preparing detailed Paper Books containing index of documents, synopsis of arguments, and appearing before the Income Tax Appellate Tribunal in Form 36 proceedings.

STATUTORY MATRIX

Statutory Provisions & Regulatory Comparative Matrix

Comparative analysis of governing sections under the new framework alongside legacy statutory references.

Tax Assessment / Litigation Proceeding	Governing Section: New Act 2025 (Old Act 1961)	Statutory Defense & Procedural Protocol
Notice for Scrutiny Assessment	The corresponding section of the Income-tax Act, 2025 (formerly Section 143(2) of Income Tax Act, 1961)	Must be issued within statutory limitation of 3 months from the end of the FY in which ITR is furnished. Point-wise technical reply mandatory.
Notice for Production of Accounts & Documents	The corresponding section of the Income-tax Act, 2025 (formerly Section 142(1) of Income Tax Act, 1961)	Questionnaire issued by NaFAC calling for ledgers, bank books, and asset details. Evidentiary substantiation required via e-proceedings.
Reopening / Reassessment Proceedings	The corresponding section of the Income-tax Act, 2025 (formerly Sections 148 & 148A of Income Tax Act, 1961)	Requires tangible material suggesting escaped income exceeding ₹50L for 5-year reopening. Rigorous challenge to notice jurisdiction and time limitation.
Best Judgment / Ex-Parte Assessment	The corresponding section of the Income-tax Act, 2025 (formerly Section 144 of Income Tax Act, 1961)	Invoked upon non-compliance with statutory notices. Requires immediate petition demonstrating reasonable cause and application for reopening.
Faceless Assessment Scheme Architecture	The corresponding section of the Income-tax Act, 2025 (formerly Section 144B of Income Tax Act, 1961)	Dynamic allocation across Assessment, Verification, and Review Units. Statutory right to request Video Conference hearing prior to adverse additions.
First Appeal before CIT(Appeals)	The corresponding section of the Income-tax Act, 2025 (formerly Section 246A of Income Tax Act, 1961)	Mandatory 30-day timeline to e-file Form 35 with concise grounds, comprehensive statement of facts, and statutory court fee compliance.
Second Appeal before ITAT	The corresponding section of the Income-tax Act, 2025 (formerly Section 253 of Income Tax Act, 1961)	60-day limitation to approach the final fact-finding authority in Form 36 with indexed paper books and legal precedents.

ONGOING GOVERNANCE

Mandatory Post-Registration Compliances

Failing to complete statutory post-incorporation actions carries steep daily penalties. Our CA firm manages continuous compliance:

Application u/s 154 / e-ProceedingsWithin 4 years from the end of FY of the order

Rectification of Apparent Errors

Online submission for rectifying mathematical or factual errors apparent from the record without filing a formal appeal.

Form 35 via e-Filing PortalWithin 30 days of service of notice of demand

First Appeal before CIT(Appeals)

E-filing Statement of Facts, detailed Grounds of Appeal, and payment of statutory appeal fees based on disputed additions.

Section 220(6) ApplicationSimultaneous with Appeal Filing

Stay of Outstanding Tax Demand

Application to Assessing Officer or appellate authority seeking stay of collection upon pre-deposit of 20% of outstanding demand.

Form 36 with Triplicate Paper BooksWithin 60 days of communication of CIT(A) order

Second Appeal before ITAT Benches

Filing before the Income Tax Appellate Tribunal against adverse appellate orders, accompanied by substantial questions of fact and law.

FREQUENTLY ASKED QUESTIONS

Statutory FAQs & Practical Guidance

Frequently asked questions and procedural guidance regarding Faceless Assessments & Appeals Representation.

What should I do immediately upon receiving a scrutiny notice on the portal?

Check the statutory section and the specified deadline. Do not ignore the notice; non-compliance triggers ex-parte assessment and severe penalties. Immediately download all questionnaire attachments, compare the queries with your filed ITR and books, and instruct your CA to prepare point-by-point factual and documentary rebuttals.

Can I request a personal hearing under the Faceless Assessment Scheme?

Yes. Under faceless assessment regulations, if a Show Cause Notice proposing a tax modification or addition is served, the taxpayer has a statutory right to request a personal hearing via Video Conferencing (VC). The Assessment Unit must grant the VC hearing before finalizing any adverse variation.

What are the limitation timeframes for reopening an assessment under Section 148 (1961 Act)?

Under the amended law, a reopening notice can generally be issued only within 3 years from the end of the relevant assessment year. It can be reopened beyond 3 years up to 5 years only if the Assessing Officer possesses information demonstrating that income escaping assessment represented in asset form amounts to or is likely to amount to ₹50 Lakhs or more.

How do I prevent the department from recovering disputed tax while my appeal is pending?

You must file a formal application for Stay of Demand under statutory provisions (formerly Section 220(6)). Under standard CBDT office memorandums, the Assessing Officer will grant a stay upon payment of 20% of the disputed demand until the disposal of the appeal by the CIT(Appeals). In cases of extreme financial hardship or glaring legal defects, writ relief or full stay can also be petitioned.

STATUTORY ADVISORY DESK • PRACTICE INQUIRIES

Statutory Inquiries & Practice Advisory

Information on Faceless Assessments & Appeals Representation is provided for general reference. Office addresses and contact details are listed on the Contact page.

Contact Practice Office +91 99140-14949