CBDT Issues Guidelines for Compulsory Complete Scrutiny of ITRs Filed in FY 2025-26
The Six Parameters for Compulsory Complete Scrutiny
| Code | Category | Selection Route |
|---|---|---|
| CS 01 | Survey u/s 133A (on or after 01.04.2024) | DGIT(Systems) with approval of DGIT(Systems), Delhi |
| CS 02 | Search u/s 132 / Requisition u/s 132A (on or after 01.04.2024) | Assessing Officer with prior approval of Pr.CIT/Pr.DIT/CIT/DIT |
| CS 03 | Notice u/s 148 already issued | Jurisdictional AO (search/survey) or NaFAC (others) |
| CS 04 | Registration/approval u/s 12A, 12AB, 35(1)(ii)/(iia)/(iii), 10(23C) — cancelled/denied on or before 31.03.2025 and claiming exemption in ITR-7 | DGIT(Systems) with approval of DGIT(Systems), Delhi |
| CS 05 | Recurring addition (law or fact) in earlier year — above ₹50 lakh (metro) / ₹20 lakh (others), now final or upheld | JAO list → Pr.CCIT → DGIT(Systems) by 15.06.2026 |
| CS 06 | Specific tax-evasion information from law-enforcement/regulatory agencies, return filed | JAO list → Pr.CCIT → DGIT(Systems) by 15.06.2026; notice via NaFAC |
Detailed Parameter-wise Analysis
Where a survey under section 133A of the Income-tax Act, 1961 — other than u/s 133A(2A) — has been conducted in the case of an assessee on or after 01.04.2024, the return is eligible for compulsory scrutiny under CS 01.
Selection mechanism: DGIT(Systems) selects cases with approval of DGIT(Systems), Delhi, based on survey case information provided by Commissioner (OSD)(Investigation), CBDT.
Notice service: Section 143(2) notice is served by the Prescribed Income-tax Authority or the Assessing Officer concerned.
Consolidated list: Pr. CCsIT/Pr. DGsIT/DGsIT(Inv.)/CCsIT(Central) must submit a consolidated list in their jurisdiction to the Commissioner (OSD)(Investigation), CBDT, in the prescribed format.
Cases lying outside Central Charges must be transferred to Central Charge within 15 days of service of notice u/s 143(2).
Where a search u/s 132 has been initiated or a Requisition u/s 132A has been made on or after 01.04.2024, the return is selected for compulsory scrutiny.
Special rule for post-01.09.2024 searches: For searches or requisitions made on or after 01.09.2024, the return selected shall be for the assessment year covered under section 158BA(6) of the Act.
Selection mechanism: The Assessing Officer selects the case with prior administrative approval of Pr.CIT/Pr.DIT/CIT/DIT concerned.
Cases lying outside Central Charges must be transferred to Central Charge within 15 days of service of notice u/s 143(2).
CS 03 covers two distinct sub-categories:
(i) Search & seizure / survey action on or after 01.04.2021 but before 01.09.2024 or survey action on or after 01.04.2021:
The Jurisdictional AO (JAO) concerned serves the section 143(2) notice where a return has been furnished. If the case lies outside central charges, Pr.CIT/Pr.DIT/CIT/DIT must transfer it to central charges u/s 127 — but only if covered under the Board’s guidelines under F.No.299/107/2013-IT(Inv.III)/1568 dated 25.04.2014. JAOs shall also upload the underlying documents on the basis of which the section 148 notice was issued.
(ii) Cases other than search/seizure/survey, where s.148 notice is issued and to be completed on or before 31.03.2027:
DGIT(Systems) forwards these cases to the National Faceless Assessment Centre (NaFAC), which will take further necessary action. The section 143(2) notice is served through NaFAC where a return has been furnished. JAOs must upload the underlying documents on which the s.148 notice was issued.
Cases where registration or approval under sections 12A, 12AB, 35(1)(ii)/(iia)/(iii), 10(23C)(iv)/(v)/(vi)/(via), etc., has been:
- Not granted, or
- Cancelled/withdrawn by the Competent Authority on or before 31.03.2025
…and the assessee has been found to be claiming tax-exemption/deduction in the return filed in ITR-7.
Exception: Where orders of withdrawal of registration/approval have been reversed or set aside in appellate proceedings, those cases will not be selected under this parameter.
Selection mechanism: DGIT(Systems) selects using this parameter with approval of DGIT(Systems), Delhi, based on returns filed by these entities in FY 2025-26.
Notice service: Section 143(2) notice is served through NaFAC or the prescribed income-tax authority. JAOs must upload the underlying documents.
Where an addition has been made in an earlier assessment year on a recurring issue of law or fact (including transfer pricing) exceeding:
- ₹50 lakh — in eight metro charges (Ahmedabad, Bengaluru, Chennai, Delhi, Hyderabad, Kolkata, Mumbai, Pune)
- ₹20 lakh — in all other charges
…and such addition has either (i) become final (no further appeal pending) or (ii) been upheld by the Appellate Authority in favour of Revenue (even if assessee’s further appeal is pending).
Procedure: JAOs prepare a list → Pr.CIT/Pr.DIT/CIT/DIT grant administrative approval → Consolidated list submitted by Pr.CIT/Pr.DIT/CIT/DIT to Pr.CCIT → Pr.CCIT forwards to DGIT(Systems) latest by 15.06.2026.
Notice u/s 143(2) is served through NaFAC.
Cases where:
- Specific information pointing to tax evasion for the relevant assessment year is provided by any law-enforcement agency, Investigation Wing, Intelligence, Regulatory Authority, or similar body; and
- The return for the relevant assessment year has been furnished by the assessee.
Important clarification: If a return has been filed in response to a notice u/s 142(1) of the Income-tax Act, 1961 — where that notice was issued based on information from NMS Cycle/AIS/Statement of Financial Transactions (SFT)/CPC-TDS/information from Directorate of I&CI — such return will not be taken up for compulsory scrutiny unless it independently falls under CS 06.
Procedure: Same as CS 05 — JAO list → Pr.CCIT → DGIT(Systems) by 15.06.2026. Notice u/s 143(2) is served through NaFAC.
Special Provisions for International Taxation & Central Charges
Cases handled by International Taxation and Central charges may be selected for compulsory scrutiny by those charges themselves, following the same prescribed parameters at Para 2, with prior administrative approval of Pr.CIT/Pr.DIT/CIT/DIT concerned.
Such selected cases shall continue to be handled by International Taxation and Central Circle charges respectively, as before. Importantly, the requirement of communicating to NaFAC for access and/or further action after selection for Compulsory Scrutiny does not apply to these charges.
Time Limit for Serving Notice u/s 143(2)
What This Means for Taxpayers & CAs
- If your client had a survey u/s 133A or search u/s 132 on or after 01.04.2024, a scrutiny notice is almost certain — watch for the 143(2) notice by 30 June 2026.
- Trusts and institutions that had their registration cancelled or denied on or before 31.03.2025 but continued claiming exemption in ITR-7 are squarely in the crosshairs under CS 04.
- Cases with recurring high-value additions that are now final or upheld (CS 05) will be selected systemically — review such clients’ pending matters proactively.
- A return filed only because a notice u/s 142(1) was received based on AIS/SFT/CPC-TDS data does not automatically trigger CS 06 scrutiny — an explicit clarification that practitioners should note.
- For CS 05 and CS 06, internal deadlines run ahead: the Pr.CCIT must submit the consolidated list to DGIT(Systems) by 15 June 2026.
Source & Reference
Circular: F.No.225/56/2026/ITA-II
Issued by: CBDT, Ministry of Finance, Department of Revenue
Dated: 4 June 2026
Signed by: Dr. Indu Bala, Deputy Secretary to the Government of India
Statutory authority: Section 536(2)(c), Income-tax Act, 2025

