Notices & Litigation Support

A defective return notice under Section 139(9) of the Income-tax Act, 1961 or Section 263(7) of the Income-tax Act, 2025 is generally issued when the income tax return is treated as defective due to incomplete schedules, wrong ITR form, missing financial details, inconsistency in income reporting, mismatch of tax paid or other technical defects. We review the exact defect mentioned in the notice, verify the return filed, identify the correction required and prepare the appropriate response. Where correction of return is required, we assist in preparing and filing the corrected return within the prescribed time. Timely action helps prevent the return from being treated as invalid and avoids avoidable refund delay or future compliance complications.

Processing intimations under Section 143(1) of the Income-tax Act, 1961 or Section 270(1) of the Income-tax Act, 2025 are generated after automated processing of the income tax return and may include adjustments on account of TDS mismatch, disallowance of deduction, arithmetical error, incorrect income reporting, tax credit mismatch, interest computation or refund adjustment. We compare the intimation with the return filed, Form 26AS, AIS/TIS, Form 16/16A, challans and other supporting records. If the adjustment is incorrect, we prepare and file rectification under Section 154 of the Income-tax Act, 1961 / Section 287 of the Income-tax Act, 2025, or an appropriate portal grievance. If the demand is valid, we advise on payment and future compliance correction.

A scrutiny notice under Section 143(2) of the Income-tax Act, 1961 or Section 270(8) of the Income-tax Act, 2025 requires a detailed and issue-wise response. The department may call for explanations relating to income, expenses, loans, investments, capital gains, cash deposits, deductions, business transactions or other matters selected for verification. We analyse the notice and questionnaire, identify each issue raised and prepare a structured reply supported by relevant documents such as bank statements, invoices, ledger accounts, confirmations, agreements, capital gain workings, investment proofs and reconciliation statements. Submissions are prepared with proper indexing, document references and factual explanation to reduce the risk of arbitrary addition, penalty initiation and unnecessary appeal proceedings.

Reassessment notices are issued where the department alleges that income has escaped assessment. Under the 1961 Act, the department generally issues a show-cause notice under Section 148A before issuing notice under Section 148. Under the 2025 Act, reassessment notice and pre-notice procedure are dealt with through the corresponding framework of Sections 280 and 281. We review the information relied upon, examine whether the income was already disclosed and evaluate legal issues such as limitation, jurisdiction, sanction approval, service of notice and procedural compliance. A detailed reply is prepared to demonstrate why reassessment is not warranted. If proceedings are initiated despite the reply, we assist in preparing submissions, compiling evidence and contesting the matter at assessment and appellate stage.

A demand notice under Section 156 of the Income-tax Act, 1961 or Section 289 of the Income-tax Act, 2025 may arise due to an assessment order, intimation, penalty order, interest computation or non-grant of tax credit. Before making payment, it is important to verify whether the demand is legally and arithmetically correct. We review the demand notice, relevant order, tax computation, TDS credit, advance tax, self-assessment tax, challans and Form 26AS/AIS records. If the demand is incorrect, we assist in filing rectification, grievance or other appropriate response. If the demand is disputed, we advise on appeal filing, stay of demand, recovery protection and refund adjustment issues.

Penalty proceedings under the Income-tax Act, 1961 or the Income-tax Act, 2025 require a separate defence and should not be treated as a routine continuation of assessment. Even where an addition is made in assessment, penalty is not automatic. The reply must clearly explain the facts, disclosure made by the assessee, bona fide conduct, reasonable cause and absence of concealment, under-reporting or misreporting, as applicable. We review the penalty notice, assessment order, facts and supporting documents, and prepare a detailed reply explaining why penalty should not be levied. Wherever applicable, we also examine immunity/waiver provisions, including Section 270AA of the 1961 Act and Section 440 of the 2025 Act, reasonable cause defence or challenge to defective penalty initiation.

Rectification under Section 154 of the Income-tax Act, 1961 or Section 287 of the Income-tax Act, 2025 is useful where there is an apparent mistake in the order or intimation. Common issues include non-credit of TDS, non-credit of advance tax, wrong interest calculation, incorrect carry-forward of loss, mismatch of challan, arithmetical error or incorrect adjustment made during processing. We prepare the rectification application with computation, Form 26AS/AIS, challans and relevant supporting records. The application is filed on the income tax portal and followed up for disposal. If the rectification order itself is incorrect, further corrective action is advised.

Where an assessment order or penalty order is adverse, a properly drafted first appeal is critical. We review the order, identify each addition, disallowance or legal error and prepare the appeal documents. Grounds of appeal are drafted precisely, with each ground linked to the relevant facts and legal position. The statement of facts presents the case background in a structured and objective manner. The paper book is compiled with notices, submissions, evidence, tax computations and relevant judicial support. Written submissions are prepared to clearly explain the relief claimed and the basis for challenge.

For matters before the Income Tax Appellate Tribunal, proper preparation of appeal papers, paper book and legal submissions under Section 253 of the 1961 Act or Section 362 of the 2025 Act, as applicable, is essential. Tribunal proceedings require clear identification of legal grounds, facts already on record, additional evidence issues and relevant judicial precedents. We assist in preparing Form 36, grounds of appeal, paper book, synopsis, written submissions and case-law compilation. We also coordinate with the advocate or arguing counsel for hearing preparation and ensure that all relevant documents are arranged in a proper, indexed and tribunal-ready format.

GST notices may be issued for ITC mismatch, GSTR-1 vs GSTR-3B difference, GSTR-2B mismatch, short payment of tax, excess ITC claim, e-way bill discrepancy, non-filing of returns, supplier default or transaction-level scrutiny. We examine the notice, identify the exact allegation and prepare reconciliation using GST returns, purchase register, sales register, invoices, e-way bills, payment records and ledger accounts. For show-cause notices under Sections 73 or 74, we prepare detailed written submissions dealing with facts, reconciliation, legal provisions and available judicial support.

GST assessment and adjudication matters require careful review of the notice, demand computation and supporting material relied upon by the department. In best judgment assessment cases, the first step may be filing pending returns and seeking withdrawal or correction of the order wherever legally available. For proceedings under Sections 73 and 74, we review the demand, prepare reconciliation, verify tax already paid, examine ITC eligibility, identify legal defects and draft a structured reply. Where an order has already been passed, we advise on rectification, appeal or other suitable remedy.

Where a GST order creates demand or denies relief, the first appeal must be drafted carefully with proper grounds, factual statement and supporting documents. The appeal should clearly explain the error in the order, factual reconciliation, legal position and relief sought. We assist in drafting the GST appeal, preparing grounds of appeal, statement of facts, written submissions and paper book. We also compute the applicable pre-deposit, assist in filing the appeal and prepare additional submissions or rejoinders wherever required during appellate proceedings.