The faceless assessment regime under the Income Tax Act is now business as usual. Most assessments and many appeals run faceless, with submissions filed online, replies drafted to the e proceeding portal and oral hearings held by video conference. The skill set has shifted from courtroom presence to written persuasion. This article distils the firm's approach to drafting effective replies.
Read the notice carefully
A surprising number of replies fail because the notice is only skimmed. Read the notice end to end before drafting. Identify the exact section under which the proceeding is held, the issues listed, the documents requested and the deadline. Note the queries that are open ended and those that point to a specific item in the return.
Structure submissions for the screen
Faceless replies are read on a screen, often by an officer with many files. Use a clean structure. Begin with a one page summary that tabulates each issue, the position in brief and a cross reference to the detailed reply. Then a separate section per issue. Then annexures listed and indexed.
Cite authority sparingly
Reasonable citation builds credibility. Pick one or two leading authorities per issue, prefer Supreme Court and the relevant High Court for the assessee's jurisdiction, and quote the operative passage rather than a long extract. Avoid bulk dumps of cases.
Prepare the reconciliation
For most issues, the officer is comparing data from third party sources with the return. Build the reconciliation that the officer needs. Ledger to GSTR. ITR to AIS. Bank statement to capital accounts. The officer reads the reconciliation, ticks the items and moves on.
Use a video hearing where allowed
The video hearing is an opportunity to clarify the harder points. Prepare a one page brief with the three points you want the officer to register. Stay concise. Confirm the points in writing through a follow up reply.
Closing
A faceless reply that is structured, factual and respectful of the officer's time tends to land. The discipline is to write less and to mean it.