Bharat Bansal Vs National Faceless Assessment Centre (Delhi High Court)
The Delhi High Court dismissed a writ petition filed under Article 226 of the Constitution challenging a notice dated 24.06.2025 issued under Section 143(2) of the Income Tax Act, 1961, by which the petitioner’s case was selected for scrutiny assessment.
The petitioner contended that CBDT circulars dated 23.06.2017 and 13.10.2021 required the Revenue to specify in the scrutiny notice the reasons for selecting the case and to indicate whether the scrutiny was limited or complete. It was argued that the impugned notice did not satisfy these requirements and was therefore invalid.
The respondent submitted that the circulars did not require the reasons for selection of a case for scrutiny to be stated in a notice under Section 143(2). It was further submitted that while the notice dated 24.06.2025 was a general notice informing the petitioner that the case had been selected for scrutiny, a subsequent notice dated 24.09.2025 under Section 142(1) of the Act sought the relevant information and documents required for the assessment.
After considering the submissions and the circulars relied upon by the petitioner, the High Court held that an Assessing Officer is not required to disclose why an assessee’s case has been selected for scrutiny. The Court observed that scrutiny assessment is intended to address the difficulties and harassment faced by assessees by confining detailed assessment proceedings to a limited number of cases.
