Section 143(2) Notice CA in Mumbai - Scrutiny Selection and Faceless Assessment

Section 143(2) of the Income Tax Act 1961 is the scrutiny selection notice. It is issued by the Assessing Officer when the return filed under Section 139 (or in response to Section 142(1)) is selected for detailed scrutiny assessment under Section 143(3). Importantly, Section 143(2) is NOT itself an inquiry or a demand - it is a NOTIFICATION that the case has been selected for scrutiny. The detailed assessment work that follows happens under Section 143(3) within the Section 144B faceless framework. Section 143(2) must be served within 3 months from the end of the financial year in which the return is furnished (Finance Act 2021 amendment effective 1 April 2021; previously 6 months). This 3-month time limit is jurisdictional - a Section 143(2) served beyond the limit is invalid and the assessment cannot proceed.

Mumbai is the LARGEST Income Tax Region in India by assessee count and tax collection. The Principal CCIT Mumbai oversees 30+ Principal CIT charges - a far higher count than any other city - covering geographical Mumbai-1 through Mumbai-30, specialised Central Charges (Section 132 search and very large corporates), International Taxation (highly active given Mumbai BFSI / shipping / pharma MNC presence), Transfer Pricing (multiple sub-charges including dedicated entertainment / film, BFSI and pharma branches), TDS and Exemption charges. Under Section 144B operational from 13 August 2020, once Section 143(2) is served, the case is allocated by NaFAC at Delhi to a Faceless Assessing Unit located anywhere in India. Mumbai unique structural advantages: the ITAT Mumbai Bench at Pratishtha Bhavan M.K. Marg is the LARGEST ITAT bench in India with multiple division benches; Bombay HC Principal Seat is also co-located - Mumbai assessees enjoy a co-location advantage that Pune (150 km to Mumbai ITAT) and Gurugram (45 km to Delhi ITAT) assessees lack.

Content is reviewed quarterly for accuracy.

The Mumbai IT Region is the LARGEST in India by assessee count and tax collection. The Principal CCIT Mumbai oversees 30+ Principal CIT charges - a far higher count than any other city. Patron Mumbai CA pod identifies the issuing charge at intake - the correct mapping determines defence strategy and DRP eligibility under Section 144C.

Mumbai Sector-Specific Section 143(2) Patterns:

• BKC / Lower Parel BFSI Indian subsidiaries: Section 92CA TP on management fees and intra-group services; ESOP perquisite Section 17(2)(vi) for senior executives; high-refund Section 244A; DRP-eligible
• Andheri-Goregaon-Vikhroli pharma HQs (Cipla, Sun Pharma, Glenmark, Lupin tier): Section 35(2AB) DSIR weighted deduction at R&D centres; Section 92CA TP on royalty / API to overseas group; capital-vs-revenue R&D characterisation
• Andheri Film City entertainment production houses: Section 37 production cost vs capitalisation; royalty receipts timing under Section 5 / 9; Section 80RR-style export of services
• South Mumbai shipping firms (Fort, Nariman Point, Colaba): Section 115V tonnage tax compliance; Section 44B presumptive shipping
• Malabar Hill / Worli / Bandra Sea Face HNIs: Section 50C real-estate consideration; Schedule FA foreign asset disclosure; ESOP perquisite; family trust Section 161 / 164
• South Mumbai trading firms: Section 40A(3) cash payment; Section 44AD presumptive vs actual; high-value AIS / TIS reconciliation

Patron Mumbai pod requires the following documents at engagement onboarding for Section 143(2) handling and Section 144B faceless workflow preparation:

Section A - The Notice:

• Copy of Section 143(2) notice (downloaded from incometax.gov.in with DIN visible)
• Any prior Section 143(1) intimation for the same AY
• Any Section 142(1) questionnaire (precedes 143(2) for non-filers or in pre-selection inquiry)

Section B - ITR and Computation:

• ITR-V acknowledgement and full ITR JSON / PDF for the relevant AY
• Detailed computation of income with all schedules
• Tax payment challans, advance tax, self-assessment tax

Section C - Income Verification:

• Form 26AS for the AY (latest version after final TDS deposits)
• AIS and TIS downloads from compliance.insight.gov.in
• Bank statements for all accounts (current, savings, FD, NRE / NRO)
• Form 16 (salary), Form 16A (TDS on other income), Form 16B (TDS on property)

Section D - Deduction and Exemption Proofs:

• Section 80C - LIC premium, PPF passbook, ELSS, NSC, tuition fees, home loan principal
• Section 80D health insurance premium, 80G donations with eligibility certificate
• HRA rent receipts, rental agreement, landlord PAN

Section E - Mumbai Sector-Specific Documents:

• BKC / Lower Parel BFSI Indian subsidiaries: TP study under Rule 10D, intra-group agreements, FTC working under Form 67, ESOP grant and exercise documentation, DRP-eligibility analysis
• Andheri-Goregaon-Vikhroli pharma HQs: Section 35(2AB) DSIR certification, R&D facility approval, expenditure breakdown capital-vs-revenue, TP study on royalty / API to overseas group
• Andheri Film City production houses: Production budget, capital-vs-revenue characterisation of production cost under Section 37, royalty receipts timing under Section 5 / 9
• South Mumbai shipping: Section 115V tonnage tax computation, vessel-wise tonnage certification, foreign-flag arrangements
• Malabar Hill / Worli HNIs: Property sale deed with Section 50C circle rate, indexed cost computation, Section 54 / 54F reinvestment, Schedule FA foreign asset disclosure backup

Section F - Property and Capital Gains:

• Property documents - sale deed, purchase deed, registration receipt with indexed cost
• Maharashtra circle rate / ready reckoner certification for Section 50C
• Section 54 / 54F / 54EC reinvestment proof for capital gains exemption

Section G - TP and International Tax (if applicable):

• TP study under Rule 10D with comparability analysis and ALP method
• Master File and CbCR (if applicable)
• DTAA documentation, Form 67 for FTC, Section 195 withholding evidence

Share your Section 143(2) notice via WhatsApp at +91 945 945 6700 and Patron Mumbai pod will revert with a written eligibility opinion, time-bar audit memo and fixed-fee Section 144B workflow quote within 2 hours during business days.

All fees and charges listed are indicative only and do not constitute a binding offer. Final amounts may vary depending on the volume of work and the complexity involved.

Professional service charges for drafting, filing, and representation are separate from the statutory fees. The exact fee depends on the complexity of the case, disputed amount, and number of hearings required. Contact us for a detailed quote.

Get a free Section 143(2) Notice Mumbai consultation - Call +91 945 945 6700 or WhatsApp us. No-obligation assessment.

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Trusted by Mumbai-based BFSI in BKC and Lower Parel (Indian subsidiaries of foreign banks, NBFCs, AMCs, insurance and fintech), Mumbai pharma HQs in Andheri-Goregaon-Vikhroli (Cipla, Sun Pharma, Glenmark, Lupin and peer companies), Mumbai entertainment / media at Andheri Film City and Bandra-Khar production houses, South Mumbai shipping firms, Malabar Hill / Worli / Bandra Sea Face HNIs, South Mumbai trading firms and Thane-Bhiwandi suburban manufacturing.

Mumbai Section 143(2) Client Coverage Spans: Section 143(2) on Section 92CA TP for management fees and intra-group services, Section 9 / 90 international tax for MNC parent receipts, ESOP perquisite Section 17(2)(vi) for senior executives, Section 244A high-refund matters, Section 35(2AB) weighted deduction with DSIR certification, Section 80HHC-style export incentives, capital-vs-revenue R&D characterisation, Section 37 production cost capitalisation, Section 115V tonnage tax compliance, Section 50C real-estate consideration, Schedule FA foreign asset disclosure and Section 161 / 164 family trust matters.

4-Office City Trust Signal: With offices in Pune, Mumbai, Delhi and Gurugram, Patron Accounting serves businesses across India - both in-person and remotely. The Mumbai office is the hub for Mumbai Section 143(2) Section 144B faceless handling, with the unique advantage of co-located ITAT Mumbai Bench (LARGEST in India) at Pratishtha Bhavan and Bombay High Court Principal Seat - eliminating inter-city travel friction for second appeals.

Section 143(2) defence pairs naturally with several Patron service lines - all delivered by the same Mumbai CA pod for a single point of accountability.

• Income Tax Notice CA Mumbai: Parent Mumbai city hub covering all income-tax notices including Section 143(2), Section 148 and Section 156.
• Section 143(2) Notice Delhi: Sibling Delhi city page - NaFAC HQ in Delhi - same Section 144B faceless workflow discipline.
• Section 143(2) Notice Gurugram: Sibling Gurugram city page - Aayakar Bhawan HSIIDC + CCIT Panchkula + NWR Chandigarh.
• Section 143(2) Notice Pune: Sibling Pune city page - ITAT Pune Bench Akurdi + Bombay HC Principal Seat Mumbai (inter-city).
• ITR for Companies: Corporate ITR filing - relevant for Mumbai corporate Section 143(2) Complete Scrutiny matters.
• Tax Audit: Section 44AB tax audit for turnover above Rs 1 crore (business) / Rs 50 lakh (profession) - clean tax audit reduces Section 143(2) trigger probability.
• GST Notice CA Mumbai: If you also have a GST notice in Mumbai - sibling Mumbai service handled by the same office.

Governing Act: Income Tax Act, 1961. Per Section 536(2)(c) of the Income Tax Act 2025, the 1961 Act continues for assessment proceedings of AY 2026-27 and earlier even after 1 April 2026 when IT Act 2025 takes effect (Section 143(2) becomes Section 271 selection notice; Section 143(3) becomes Section 271 assessment order).

Section 143(2) IT Act 1961 (Income Tax Department): Scrutiny selection notice. NOT itself an inquiry or demand.

Section 143(2) Proviso (Time Limit): Service within 3 months from end of FY of ITR furnishing (Finance Act 2021 amendment effective 1 April 2021; previously 6 months). Jurisdictional limit.

Section 143(3) IT Act 1961: Scrutiny assessment order; under Section 144B faceless framework from 13 August 2020.

Section 144B IT Act 1961 (e-Filing Portal): Faceless Assessment Scheme - NaFAC Delhi allocates cases to FAUs across India. All communication through e-filing portal.

Section 142(1) IT Act 1961: Inquiry / requisition during Section 143(3) workflow - FAU issues multiple questionnaires.

Section 144 IT Act 1961: Best judgment assessment - where assessee fails to comply with Section 142(1) / 143(2). Adverse default route.

Section 144C IT Act 1961 - DRP: Dispute Resolution Panel for eligible assessees (foreign companies, TP cases); draft-order objections within 30 days; DRP order within 9 months. Heavy Mumbai usage.

Section 153 IT Act 1961: Assessment time limit - 12 months from end of AY; 21 months where Section 92CA TP reference made.

Section 154 IT Act 1961: Rectification of mistake apparent from record - alternative to appeal for arithmetic errors.

Section 246A IT Act 1961: CIT(A) appeal jurisdiction for Section 143(3) orders; 30-day window from order; 20 percent pre-deposit.

Section 253 IT Act 1961: ITAT second-appeal jurisdiction; 60 days from CIT(A) order; ITAT Mumbai Bench at Pratishtha Bhavan M.K. Marg handles Mumbai appeals - LARGEST in India.

Section 260A IT Act 1961: High Court appeal on substantial question of law from ITAT order; 120 days; Bombay HC Principal Seat at Mumbai (co-located with ITAT Mumbai Bench).

Section 270A IT Act 1961: Penalty for under-reporting (50 percent of tax) or mis-reporting (200 percent) of income.

Section 270AA IT Act 1961: Immunity from Section 270A penalty where conditions met.

CASS (Computer-Assisted Scrutiny Selection): CBDT annual instruction sets CASS parameters, scrutiny categories (Limited / Complete / Compulsory) and procedural workflow.

Faceless Appeal Scheme 2021: Effective 6 September 2021; National Faceless Appeal Centre allocates CIT(A) appeals.

IT Act 2025 Transition (1 April 2026): Section 143(2) becomes Section 271 (selection); Section 143(3) becomes Section 271 (assessment); faceless scheme provisions carried forward.

Penalty and Process Snapshot:

• Section 143(2) issuance deadline: 3 months from end of FY of ITR filing (jurisdictional)
• Section 270A under-reporting penalty: 50 percent of tax; mis-reporting: 200 percent
• Section 144 best-judgement: typically 3 to 5x higher demand than properly defended scrutiny
• Section 144C(2) DRP objections: 30 days from draft order (eligible assessees)
• Section 153 order limit: 12 months from end of AY (21 months for TP)
• Section 246A appeal pre-deposit: 20 percent of disputed demand
• ITAT Mumbai Bench: second appeal at Pratishtha Bhavan (LARGEST in India, co-located)

Deadline: Once Section 143(2) is served, the case is allocated by NaFAC Delhi to a Faceless Assessing Unit anywhere in India within days. Section 142(1) questionnaire windows of 15 to 30 days follow. Missing any window allows Section 144 best-judgement assessment with adverse additions.

Mumbai Penalty Exposure: For a Rs 1 crore Mumbai Section 143(3) addition under Complete Scrutiny, Section 270A penalty exposure ranges from Rs 50 lakh (under-reporting 50 percent of tax) to Rs 2 crore (mis-reporting 200 percent of tax). Most Mumbai assessees are unaware of the 3-month Section 143(2) proviso time-bar defence.

Time-Bar Defence: If your Section 143(2) was issued beyond the 3-month proviso window from end of FY of ITR filing, Patron files Article 226 writ before the Bombay HC at Principal Seat (co-located with our Mumbai office). Bombay HC has consistent precedent striking down time-barred Section 143(2) notices.

Action: Forward your Section 143(2) notice to Patron Mumbai. Call +91 945 945 6700 or WhatsApp the notice copy. Free 30-minute notice review with Section 143(2) time-bar check, CASS category decode and Mumbai IT charge identification. We respond within 2 hours during business days.

A Section 143(2) scrutiny selection notice in Mumbai is the AO notification that your case has been selected for Section 143(3) assessment under the Section 144B faceless framework. Section 143(2) is NOT itself a demand or inquiry; it is a selection notice. The Section 144B workflow that follows operates through NaFAC Delhi allocation to a Faceless Assessing Unit anywhere in India - with Mumbai assessees additionally having Mumbai TPO physical hearings for TP cases and DRP physical hearings under Section 144C at Mumbai DRP.

Mumbai is the LARGEST IT Region in India with 30+ Principal CIT charges - geographical Mumbai-1 to Mumbai-30, Central Charges (Section 132 search), International Taxation, Transfer Pricing (multiple sub-charges including entertainment / film, BFSI and pharma), TDS and Exemption. The ITAT Mumbai Bench at Pratishtha Bhavan M.K. Marg is the LARGEST ITAT bench in India with multiple division benches; Bombay HC Principal Seat is co-located - Mumbai assessees enjoy unique no-inter-city-travel advantage for second appeals.

Patron Accounting LLP runs a dedicated Mumbai Section 143(2) pod with sector-specific defence playbooks for BKC / Lower Parel BFSI TP, Andheri-Goregaon-Vikhroli pharma Section 35(2AB) and royalty TP, Andheri Film City Section 37, South Mumbai shipping Section 115V, and Malabar Hill / Worli HNI Section 50C and Schedule FA matters. Pricing Rs 25,000 to Rs 50,000 per matter; TP / international tax priced higher. Call +91 945 945 6700 | WhatsApp +91 945 945 6700 | Email sales@patronaccounting.com. Free 30-minute notice review with Section 143(2) time-bar check.