Email from Income Tax Department: "Notice under section 143(2) of the IT Act has been issued". Your heart rate goes up. It is scrutiny. A detailed review of your ITR by the Assessing Officer. It happens in 0.2-0.5% of returns; scrutiny selection is partly random, partly risk-based (high-value transactions, foreign assets, large refund claims). Respond calmly within 15 days, and most 143(2) cases resolve in 3-6 hearings over 6-12 months. Ignore it, and best-judgement assessment under 144 can add 30-300% penalty.
By the end, you will know the four notice types you may receive, the difference between 143(2) scrutiny and 148 reopening, the structured response framework, and when to engage a CA.
Four notice types
143(1). Automated processing intimation (low stakes, covered in earlier article).
143(2). SCRUTINY selection. AO will review ITR in detail, ask questions, demand documents.
148. RE-OPENING assessment. AO suspects income escaped assessment in an earlier year.
139(9). DEFECTIVE return (fix and refile within 15 days).
The subject line and section reference are the first clues. 143(2) is "scrutiny" or "notice for assessment". 148 is "reassessment" or "notice under section 148". 143(1) is "intimation" (one-sided communication, not a notice demanding response). Misreading 143(2) as 143(1) is the common anxiety error; usually the notice is clear once read carefully.
The 143(2) response framework
Confirm receipt on e-filing portal within 15 days (login to "e-Proceedings" to acknowledge receipt).
AO sends QUESTIONNAIRE under section 142(1) asking for specific documents / clarifications.
Submit documents digitally or in person within given time (typically 30 days per questionnaire).
Attend video / in-person hearings if called (post-2020 most hearings are virtual via the Faceless Assessment Scheme).
AO issues FINAL ASSESSMENT ORDER under section 143(3). Typically 12-24 months from notice.
Timeline: 143(2) must be issued within 3 months from end of financial year in which return was filed. Final assessment order must be completed within 21 months from end of AY. Post-2020 Faceless Assessment Scheme: AO may not be in your jurisdiction; hearings are virtual; documents submitted digitally. Reduces anxiety but requires discipline with electronic submissions.
Section 148. Reopening assessment
Section 148 can re-open returns: up to 3 years old for normal reopening; up to 10 years if income escaped assessment > Rs. 50 lakh (Budget 2021 changes). Strict, document-heavy. The AO must have "reason to believe" that income has escaped assessment. Usually triggered by third-party reports (foreign account info from DTAA partners, FIU-IND STR, major bank transaction reports).
Response to 148: taxpayer files fresh ITR for the reopened year within 30 days, then the assessment follows the regular 143(2) to 143(3) track. 148 cases are more serious than 143(2); engage a CA familiar with reassessment proceedings. Settlement via Vivad se Vishwas schemes (when available) or tribunal appeals are longer-term options if assessment is adverse.
148 reopens old returns
Section 148 can re-open returns up to 3 years old (10 years if escaped income > Rs. 50 lakh). Strict, document-heavy. Engage a CA familiar with reassessment proceedings. The stakes are high and the legal procedure is technical.
148 reopens old returns
Section 148 reopens up to 3 years (10 years for > Rs. 50L escaped income). Strict. Engage a CA for 148 cases; stakes are higher than 143(2).
Faceless Assessment Scheme post-2020
Most 143(2) proceedings post-2020 are virtual under Faceless Assessment Scheme. AO may not be in your jurisdiction; hearings via video; documents digital. Reduces travel but requires digital responsiveness.
Best-judgement assessment under 144
Ignoring 143(2) or 148 = AO completes best-judgement assessment under section 144. Department picks its own numbers. Penalty 30-300% under 270A for under-reporting. Respond promptly; non-response is the worst strategy.
Respond to 143(2) within 15 days; confirm receipt on portal.
3-6 hearings typical, mostly virtual post-2020 under Faceless Assessment Scheme.
Engage a CA for 143(2) + 148 cases; self-handling is risky for complex scrutiny.
Keep all supporting documents for 8 years (supports potential re-opening under section 148).
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Filing + edge cases covered. The next category is specialist CA / CMA / CFA exam prep. Where the same concepts are framed for professional exams rather than filers.
