ISSUE FOR CONSIDERATION
A notice under s. 143(2) is required to be served by the Assessing Officer(‘AO’) or the prescribed Income Tax Authority, to the assessee, in a case where the AO considers it necessary to ensure that the assessee has not understated the income or has not claimed excessive loss or has not under-paid the taxes. Such a notice shall call upon the assessee to attend the office of the AO or to produce evidence in support of the return of income on a date specified in the notice. This notice shall be served before the expiry of 3 months from the end of the financial year in which the return is furnished. No form or the format for issue of the notice has been prescribed in s.143(2) of the Act.
Under the powers vested u/s. 119 of the Act, the Central Board of Direct Taxes (''CBDT''), vide Notification No. 225 / 157 / 2017 / ITA. II dt. 23rd June, 2017 has prescribed the modified formats for issue of the notice under s.143(2) by the AO where a case of an assessee is selected for scrutiny. The formats require the AO to inform the assessee that his case is selected for scrutiny and also inform that the scrutiny would be limited or complete, besides informing him that the proceedings will be conducted manually or electronically. Three separate formats have been prescribed to be used based on the nature of scrutiny or return. The N