Practice Brief • Income Tax & Direct Taxation
Tax Scrutiny Defense & Appeal Representation
Defense against Section 143(3) scrutiny, Section 148 reassessment notices, and appeals before CIT(A) & ITAT.
Turnaround: Urgent 24-hour response for statutory notices; case-specific litigation timelines
Practice Lead: CA. R.A. Dhoot, Principal Chartered Accountant (FCA, DISA)
Practice Methodology & Regulatory Scope
When routine compliance escalates to disputes, our litigation cell steps in with deep statutory mastery and judicial precedents. We formulate strategic grounds of appeal, prepare meticulous paper books, and represent clients before appellate authorities and the Income Tax Appellate Tribunal (ITAT).
Governing Statutory Acts & Guidelines
Chapter XIV & XX of Income Tax Act
Section 148A Procedure
ITAT Rules 1963
Vivad se Vishwas Scheme provisions
Tangible Client Deliverables
1
Drafting technical replies to Section 148A, 143(2), and 142(1) scrutiny notices2
Preparation of Statements of Facts & Grounds of Appeal for CIT(Appeals) / NFAC3
Direct representation before the Income Tax Appellate Tribunal (ITAT)4
Stay of demand petitions before Assessing Officers and Principal Commissioners5
Penalty defense proceedings under Section 270A / 271AACMeasurable Enterprise Safeguards
High success rate in quashing arbitrary additions and disallowed expenses
Stay of aggressive demand collections to preserve working capital
Settlement of legacy disputes through statutory dispute mitigation schemes
Statutory Practice FAQs
Q: What should we do if we receive a Section 148 notice for income escaping assessment?
A: Section 148 requires a time-bound reply within the specified statutory period. We immediately verify whether prerequisite conditions under Section 148A (sanction from specified authority, monetary threshold of ₹50L for cases beyond 3 years) are satisfied, and draft a robust technical reply challenging jurisdiction and factual allegations.
Partner Consultation
Engage Practice Partner
Schedule an in-person chambers discussion or encrypted virtual conference with our senior practice leader.
Designated Partner Lead:
CA. R.A. Dhoot, Principal Chartered Accountant (FCA, DISA)
ICAI Fellow Chartered Accountant
Strict client confidentiality maintained under ICAI Code of Ethics.