Defending Section 143(2) and Section 148 Faceless Scrutiny Notices

Build a paper book before you write

Start with a paginated set, not with a letter. Index every exhibit. The covering submission then points to page numbers. Officers working through a queue will not hunt through an unlabelled PDF.

• Return and computation: The filed ITR, computation, and tax audit report if applicable, so the officer can see what was already disclosed.

• AIS and 26AS reconciliation: A line-by-line match of reported receipts against AIS, with a note for every unmatched row.

• Primary evidence: Bank statements, invoices, sale deeds, loan confirmations, or stock records that prove the figure in the return.

• Explanations for gaps: Where AIS shows a receipt that is not income, say so in one paragraph and attach the contra evidence.

AIS mismatches are the usual trap

Most faceless files open because AIS and the return do not tell the same story. Duplicate reporting by a bank and a registrar, a property value reported at agreement value rather than the amount received, or interest that belongs to another PAN are routine. Do not argue that AIS is unreliable in the abstract. Show the duplicate, the other PAN, or the capital-versus-revenue split with documents.

Deadlines and what not to do

Portal due dates are short. Ask for an adjournment in writing if the paper book is still being assembled, and still file a partial response that covers the issues you can prove today. Silence is treated as having nothing to say. Do not upload password-protected files, scans that cannot be read, or a dump of the entire accounting folder without an index.

When the practice takes the file

We treat a 143(2) or 148 notice as a scoped engagement: notice analysis, AIS recon, paper book, and the portal submission. Related-party and cash-deposit files need more time because the evidence sits across banks and associated entities. Start as soon as the notice is received; the portal clock does not pause for a complete set of books.