TaxTMI 
TaxTMI 
Notice u.s. 143.2 for AY 2025-26:
Time limit:
As per the proviso to section 143(2) of the Income-tax Act, 1961 and also read with section 536(2)(c) of the Income-tax Act, 2025, the time limit for service of notice u/s 143(2) of the Income-tax Act, 1961 for the ITRs filed in the Financial Year (FY) 2025-26 is 30.06.2026.
This is also mentioned in the recent Circular vide F.No.225/56/2026/ITA-II dated 04.06.2026 about Guidelines for Compulsory Selection of returns for Complete Scrutiny during the Financial Year 2026-27.
Author believe that this circular is only for cases of complete scrutiny and not other type of scrutiny like scrutiny as per CASS, complete scrutiny, limited scrutiny manual scrutiny etc.
Notices u.s. 143(2) have been received by many assessee. These are as per standard formats with minor changes. On perusal of some notices, author felt it desirable to prepare a suitable preliminary draft reply which can be used with necessary modifications.
Such draft is appended below:
Name, address and PAN of assessee
To,
{GOVERNMENT OF INDIA
MINISTRY OF FINANCE
INCOME TAX DEPARTMENT
Assistant Commissioner of Income Tax/
Deputy Commissioner of Income Tax (International Taxation), Circle -1(1)(1), Delhi
Prescribed Income-tax Authority } - as mentioned in the notice
ACIT, IT Circle --------- Income tax department. - As mentioned besides digital signature.
Sir,
I find that number of authorities ( three ) are mentioned, and all are valid since anyone is not ticked and others are not strike out. Fourth authority is found at place of digital signature.
Furthermore, signature validation status mention as follows:
It is mentioned that 'Document was certified, validity is UNKNOWN'
What this means?
As a layman, I can only understand that the validity of document is not known. Whereas, validity must be known and it should be apparent to the addressee / noticee / addressee.
If the Departmental document itself says validity is unknown, then how an assessee can consider it as a valid notice? In any case it is a valid point of concern for assessee as to whether he has been served a valid notice?
This is a new aspect I am finding for the first time.
Kindly enlighten to me in this regard about validity of notice.
My preliminary reply,
Without prejudice to my above observations I submit as follows:
The notice is silent about mode of selection and scope of scrutiny.
The notice is also silent about prior approval of any specified authority.
If these aspects are applicable, I request you to provide information and copy of prior approval.
Defect, if any, in the notice can be rectified within limitation period that is on or before 30.06.2026.
Regarding ROI:
I had filed my ROI as per accounts prepared as per normal accounting practices, as in earlier years consistently followed.
Computation of income has also been made as per precedence and applicable law, as I understand as a businessman with assistance of accountants and auditors.
There are no aspect of any disputes on any facts and law for the year as per recent past 3 / 5 assessments years.
One old dispute which is pending in appeal is on peculiar facts( of survey and prejudiced additions made for that year). This has no impact in this year because in the present year there is no such situation.
A substantial question of law is pending before High Court for AY 2013 -14, this issue is not involved in AY 25-26 and he issue was not of recurring nature, no addition or dispute is pending after AY 2013-14 on that issue.
Information available from other agencies as reflected in Form 26AS, AIS and TIS and communications from other authorities received by assessee have been tallied.
There can be some difference due to timing difference in reporting and accounting. However, such difference, if any, are adjusted over a period of time of maximum three years - one earlier year, current year and one next year.
Such differences can be due to timing difference only. Therefore, for such differences, if any,any addition is not required.
Normal documents like Return of income, Tax audit report, TDS and TCS returns, cover major documents and information which are of final nature and form part of major information relevant for assessment.
In the notice any specific requisition is not made. In case I am served with any notice calling for further information and documents, I will submit the same.
Assuring you my best possible cooperation,
Yours faithfully,
Assessee