This compilation indexes twelve income-tax rulings — spanning multiple ITAT benches and three High Courts — that engaged Section 143(2) of the Income Tax Act, 1961 between March and May 2026. The rulings arise in diverse procedural contexts: scrutiny of regular returns, block-period search assessments, reassessment proceedings, and writ challenges before High Courts. The compilation is intended for in-house tax teams, Big-4 associates, and law-firm researchers who need a structured, court-sourced reference point for recent judicial activity around scrutiny notices.

Research index only. This page is a structured case-law reference. Nothing on this page constitutes legal advice, tax advice, or a recommendation to take any action. Always verify the full text of each judgment and consult qualified counsel before acting on any ruling.

The statutory framework in one paragraph

Section 143(2) of the Income Tax Act, 1961 empowers an Assessing Officer to serve a notice on an assessee — after a return has been furnished under Section 139 or in response to a notice under Section 142(1) — requiring the assessee to attend or to produce, or cause to be produced, any evidence on which the assessee may rely in support of the return. Such a notice must be served before the expiry of six months from the end of the financial year in which the return is furnished. The notice is the jurisdictional gateway to a scrutiny assessment under Section 143(3); its validity, format, and timely issuance are therefore threshold questions that frequently arise in appellate proceedings.

The 12 rulings

1. Siva Brahma Narayana Chowdary vs The ACIT, Central Circle, Vijayawada

Bench: Income Tax Appellate Tribunal - Vizag
Date: 13 May 2026
Sections engaged: 54F, 143(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before the Visakhapatnam Bench in ITA No. 13/Viz/2026 for Assessment Year 2018-19. Per the source preview, the assessee — a Doctor and Managing Director of M/s Vignesh Super Specialty Hospitals Private Limited — had filed a return of income for AY 2018-19 on 31/07/2018 declaring an income of Rs. 27,21,230/-, which was initially processed under Section 143(1); a survey under Section 133A was subsequently conducted on the hospital entity on 21/03/2019, giving rise to the proceedings under challenge.

2. ACIT, Central Circle-2, Patna vs Md. Illyas Hussain, Patna

Bench: Income Tax Appellate Tribunal - Patna
Date: 13 May 2026
Sections engaged: 143(2), 143(3), 292B
Outcome: Outcome not specified in source
Procedural / substantive ground: This is a revenue appeal in IT(SS)A 8/PAT/2019 covering Assessment Years 1989-90 to 1998-99. Per the source preview, one of the revenue's stated grounds was that the CIT(A) erred in not considering that, in the absence of a return required to be furnished by the assessee in response to a notice under Section 158BC, a notice under Section 143(2) cannot be given — raising the question of whether issuance of a Section 143(2) notice is a valid procedural step in block assessment proceedings absent the requisite return.

3. Sonaj And Company, Solapur vs DCIT Circle 2(2), Solapur

Bench: Income Tax Appellate Tribunal - Pune
Date: 6 May 2026
Sections engaged: 143(2), 147
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal before the ITAT Pune "B" Bench in ITSSA No. 30/PUN/2025 pertains to Assessment Year 2000-01 (AY 1990-91 per the CIT(A) order reference in the preview). Per the source preview, the assessee is a partnership firm engaged in dealing in petroleum products, Hero Honda motorcycle spare parts, and other commodities; a search and seizure action under Section 132 was conducted on 21/07/1999, and a notice under Section 158BC was subsequently issued on 15/10/1999 requesting the assessee to furnish a return of income for the block period 1990-1991 to 1999-2000, forming the backdrop against which Section 143(2) and Section 147 are engaged.

4. Chandra Veer Soni, Jodhpur vs DCIT/ACIT Circle, Barmer

Bench: Income Tax Appellate Tribunal - Jodhpur
Date: 29 April 2026
Sections engaged: 143(2), 145(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: In ITA No. 1106/Jodh/2025 for Assessment Year 2017-18, the assessee challenged the validity of the assessment order on the ground that the notice issued under Section 143(2) was not issued in the specifically prescribed format as per CBDT instructions bearing F.No. 225/157/2017/ITA.II. The assessee's counsel argued that departure from that prescribed format rendered the assessment framed on the basis of such notice invalid.

5. Reliance Industries Limited vs Additional/Joint/Deputy

Bench: Bombay High Court
Date: 22 April 2026
Sections engaged: 143(2), 142(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: Reliance Industries Limited filed multiple writ petitions before the Bombay High Court — including Writ Petition Nos. 4001, 3359, and 2980 of 2025 — challenging notices issued under Section 143(2) and Section 142(1) of the Income Tax Act, 1961 and the proceedings thereto in respect of different assessment years. Per the source preview, the petitioner-company sought judicial review of these scrutiny and requisition notices before the court could examine the substantive merits of the assessment proceedings.

6. M/S Jugeshwar Prasad Memorial Trust vs ITO, Exemption Ward, Hazaribagh

Bench: Income Tax Appellate Tribunal - Ranchi
Date: 20 April 2026
Sections engaged: 143(2), 119
Outcome: Outcome not specified in source
Procedural / substantive ground: In ITA No. 463/Ran/2025 for Assessment Year 2017-18, the assessee's representative submitted before the Ranchi Bench that the notice issued under Section 143(2) was not in the prescribed format as revised by the CBDT for the impugned assessment year. The assessee's AR argued that the subsequent proceedings initiated after issuance of such a notice are invalid and invalid ab initio — directly placing the CBDT-format requirement at the centre of this appeal.

7. Commissioner Of Income Tax vs M/S Pentasoft Technologies Ltd

Bench: Madras High Court
Date: 16 April 2026
Sections engaged: 10A, 143(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This Tax Case Appeal (T.C.(A) No. 631 of 2010) before the Madras High Court arose from an ITAT Madras "B" Bench order dated 24/03/2008 in ITA No. 2148/Mds/2007. Per the source preview, M/s Pentasoft Technologies Limited filed its return of income for Assessment Year 2003-2004 on 01/12/2003, admitting a loss of Rs. 43,72,45,148/- after claiming an exemption under Section 10A; the case was selected for scrutiny under Section 143(2), and, as the aggregate value of foreign transactions exceeded Rs. 5 crores, it was referred to the Transfer Pricing Officer (TPO).

8. Incometax Officer Ward-2 3 4, Surat vs Sureshbhai Vashrambhai Khunt, Surat

Bench: Income Tax Appellate Tribunal - Surat
Date: 15 April 2026
Sections engaged: 142(1), 143(2), 144, 147, 148, 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: Three cross-appeals — ITA No. 379/SRT/2024 (AY 2009-10) filed by the Revenue, and ITA Nos. 658 & 659/SRT/2024 (AY 2009-10 and AY 2010-11) filed by the assessee — were heard together before the ITAT Surat Bench. Per the source preview, the appeals arose from separate orders of the National Faceless Appeal Centre (NFAC) dated 09/02/2024, and the proceedings involved questions spanning reassessment, unexplained money, and the interaction of multiple procedural provisions including Section 143(2).

9. Nitin Jindal, Bathinda vs Income Tax Officer Ward 1(1), Bathinda

Bench: Income Tax Appellate Tribunal - Amritsar
Date: 8 April 2026
Sections engaged: 143(2), 145(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: Two appeals — ITA Nos. 145 & 146/Asr/2025 — for Assessment Years 2016-17 and 2017-18 were filed by the assessee before the Amritsar Bench against the CIT(A) NFAC order dated 04/12/2024, which in turn arose from assessment orders dated 30/12/2018 and 23/12/2019 respectively passed by ITO Ward-1(2), Bathinda. Per the source preview, the appeals engage Section 143(2) alongside Section 145(3) in the context of those scrutiny assessments.

10. M/S. PVP Corporate Parks vs The Deputy Commissioner Of

Bench: Madras High Court
Date: 30 March 2026
Sections engaged: 143(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This Tax Case Appeal (T.C.A. No. 636 of 2016) was filed before the Madras High Court under Section 260A of the Income Tax Act, 1961 against an ITAT Chennai Bench "C" order dated 01/08/2016 in ITA No. 497/Mds/2018. Per the source preview, the substantive dispute involved profit on sale of properties — including figures related to properties at 100 ft. Road, Saligramam, Vadapalani and KRM Centre, Harrington Road, Chetpet — with Section 143(2) forming part of the procedural framework of the underlying assessment.

11. Vyavasaya Seva Sahakari Sangh Ltd vs The Assessment Unit

Bench: Karnataka High Court
Date: 27 March 2026
Sections engaged: 143(2), 272A(1)(d)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner, a cooperative society registered under the Cooperative Credit Society Act, 1959, filed Writ Petition No. 101431 of 2026 before the Karnataka High Court at Dharwad under Articles 226 and 227 of the Constitution of India seeking certain reliefs against the National Faceless Assessment Centre and the local Income Tax Officer. Per the source preview, the writ petition was listed for preliminary hearing, placing Section 143(2) and Section 272A(1)(d) before the court at an early procedural stage.

12. Jitendra Arya, Indore vs ITO 1(3), Indore

Bench: Income Tax Appellate Tribunal - Indore
Date: 25 March 2026
Sections engaged: 143(2), 148
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA No. 386/Ind/2025 for Assessment Year 2011-12 was filed before the ITAT Indore Bench against the CIT(A)-NFAC order dated 22/02/2025, which arose from an assessment order dated 10/12/2018 passed by ITO-1(3), Indore under Sections 147 and 148 read with Section 143(3) of the Act. Per the source preview, the assessee-individual had filed his return of income for AY 2011-12, and the appeal addresses both the reassessment jurisdiction under Section 148 and the role of Section 143(2) in those proceedings.

Patterns across these 12 rulings

CBDT-prescribed format as a standalone ground of challenge. At least two cases in this compilation — Chandra Veer Soni (Case 4) and M/S Jugeshwar Prasad Memorial Trust (Case 6) — explicitly raise the argument that a Section 143(2) notice not issued in the format prescribed by CBDT instructions renders the consequent assessment invalid ab initio. This indicates an active litigation trend around format compliance as a jurisdictional objection.
Section 143(2) in block-assessment and search contexts. Cases 2, 3, and 8 all arise in the context of search-and-seizure or block-period proceedings, where the interaction between Section 143(2) and special assessment provisions (including Section 158BC and Section 144) generates distinct procedural questions around whether a standard scrutiny notice can be issued in the absence of or prior to a block return.
Reassessment proceedings combining Sections 148 and 143(2). Cases 8 and 12 both involve assessments framed under reassessment provisions alongside Section 143(2), confirming that scrutiny-notice validity remains a live issue even within the reassessment framework rather than only in regular-return scrutiny.
High Court writ jurisdiction invoked against Section 143(2) notices. Three of the twelve rulings — Reliance Industries (Case 5), M/S PVP Corporate Parks (Case 10), and Vyavasaya Seva Sahakari Sangh (Case 11) — involve High Court proceedings under Articles 226/227 or Section 260A, demonstrating that parties continue to seek extraordinary remedies at the notice stage rather than exhausting only the appellate hierarchy.
Section 143(2) as a gateway to multi-issue substantive disputes. Several cases — including Commissioner of Income Tax vs Pentasoft Technologies (Case 7), involving a Section 10A exemption claim and Transfer Pricing reference, and Nitin Jindal (Case 9), involving Section 145(3) — show that Section 143(2) frequently appears as part of a broader procedural and substantive framework rather than as the sole issue, making scrutiny-notice validity a recurring threshold question in otherwise substantively complex assessments.

How to use this compilation

This compilation is a starting-point index, not a comprehensive digest. Each entry identifies only the parties, forum, date, sections engaged, and the limited procedural or substantive ground visible from the source preview. The full text of each judgment — including the operative order, the tribunal's or court's reasoning on each ground, and any concurring or dissenting notes — must be retrieved from the relevant court portal (indiankanoon.org, the Madras High Court's judis portal, the Karnataka High Court's website, or official ITAT order repositories) and read in its entirety before any reliance is placed on a ruling.

Researchers should additionally verify whether any of these orders have been stayed, reversed, or distinguished in subsequent proceedings. ITAT orders are subject to appeal before the respective High Court under Section 260A, and High Court orders may be challenged before the Supreme Court; a ruling that appears final in this index may have been overturned or qualified after the date of this compilation. Similarly, CBDT circulars and instructions — several of which are directly referenced in the cases on the format of Section 143(2) notices — may have been amended or withdrawn; the current version of any instruction should be confirmed from the CBDT's official notifications.

For cases involving block assessments, reassessment, or faceless assessment proceedings, researchers should cross-reference applicable CBDT notifications, Finance Act amendments, and any Supreme Court or High Court precedent on the jurisdictional requirements of Section 143(2) that may bind the benches cited here. The fact that all outcome fields in this compilation read "Outcome not specified in source" reflects the limits of the source preview and does not indicate that the appeals were undecided — full orders should be consulted to determine the operative direction.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 143(2) Scrutiny Notices: 12 Recent ITAT and HC Rulings (2026)