GST Disputes & Appeals
Show-cause notices, ITC denials, demands and appeals.
Tax Disputes
Income Tax Disputes
Assessment outcomes turn on documentation and procedure, not only on the law.
The Problem
What Is at Stake
Assessment outcomes increasingly turn on documentation and procedure, not only on the law. In faceless assessment, the officer knows the taxpayer only through what is uploaded. A response that is incomplete, late or hard to follow is decided on what is in the record, and gaps tend to be filled with additions.
The law itself is in transition. The Income-tax Act, 2025 replaces the Income-tax Act, 1961, renumbering provisions and restructuring procedure. Assessments and appeals for earlier years continue to refer to the old Act, while new notices may cite the new one. Getting the section, the time limit and the forum right for each year is the first task in any income tax matter.
KP Juris analyses notices and orders, prepares responses and appeals, and works with chartered accountants and authorised representatives who appear before the income tax authorities and the Tribunal.
Scope
Matters We Advise On
- Scrutiny assessment notices
- Reassessment notices for income escaping assessment
- Demand notices and recovery
- Stay of demand applications
- First appeals against assessment orders
- Appeals before the Income Tax Appellate Tribunal
- Penalty proceedings
- Rectification of mistakes apparent from the record
Approach
How We Approach It
01
Identify the law and the year
Confirm which Act governs the proceeding, the provision invoked and the time limits that apply.
02
Organise the evidence
Assemble returns, books, bank records and agreements into a response the assessing officer can follow.
03
Respond on facts and procedure
Address each query, and challenge jurisdiction or limitation where the notice is defective.
04
Plan the appeal path
If an addition is made, assess the appeal, the stay of demand and any penalty exposure together.
Key Considerations
What to Know Before You Act
Transition to the 2025 Act
Section numbers differ between the 1961 and 2025 Acts. A notice that cites the wrong Act for the year concerned should be examined carefully.
Response timelines
Faceless proceedings run to the deadlines set in each notice. Adjournments are possible but not automatic, and silence is treated as non-compliance.
Stay of demand
Filing an appeal does not stop recovery. A stay must be requested, and the department commonly expects payment of part of the demand as a condition.
Reassessment time limits
Reassessment can be started only within set periods after the end of the relevant year, with a longer period where larger amounts are involved. Notices beyond the limit can be challenged.
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