Scrutiny is a written case, not a conversation

Especially under the faceless assessment framework, your entire case is made through what you submit in writing. A submission that's disorganised or incomplete doesn't get a second chance to clarify informally — treat every submission as the complete case for that point.

Structure that works

  1. Address each query in the order it was raised — don't consolidate everything into one undifferentiated response
  2. State your position clearly upfront for each point, then support it with evidence and reasoning
  3. Reference specific documents by annexure number, so the officer can verify claims without hunting through unlabelled attachments
  4. Cite the legal basis — provisions, circulars, or precedent — for any interpretive position, not just factual assertions

Evidence that actually persuades

Mistakes that weaken a submission

Why the first submission matters most

A well-prepared first response often resolves a query without further escalation. A weak first response frequently generates follow-up queries or, worse, an adverse finding that then has to be challenged on appeal — a considerably harder and more expensive path than getting it right at scrutiny.

This article provides general guidance for educational purposes and reflects our understanding of the law as of the publication date. It is not a substitute for professional advice tailored to your specific facts. Tax and regulatory provisions change, and thresholds/deadlines should always be verified at the time of action. Please speak with our team before relying on this for a specific decision.
Need help with this directly? See our Tax Litigation & Appellate Representation →
CR
CA Rajesh Bhagat
International Tax Partner · VRKSJP & Co

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