CBDT Issues Guidelines for Compulsory Complete Scrutiny Selection for FY 2026-27 | TaxRoutine New

Compulsory Complete Scrutiny
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CBDT Issues Guidelines for Compulsory Complete Scrutiny Selection for FY 2026-27 | TaxRoutine
📋 CBDT Circular · F.No.225/56/2026/ITA-II · Dated 4 June 2026
Income Tax · Scrutiny Assessment

CBDT Issues Guidelines for Compulsory Complete Scrutiny of ITRs Filed in FY 2025-26

📅 7 June 2026 📁 Income Tax · Assessments ⏱ 5 min read
The Central Board of Direct Taxes (CBDT) has issued its annual guidelines prescribing the parameters and procedures for compulsory selection of income-tax returns filed during FY 2025-26 for complete scrutiny in FY 2026-27. Six categories of cases — CS 01 through CS 06 — are notified. The deadline for serving the section 143(2) notice is 30 June 2026.

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

CS 01 Cases Pertaining to Survey u/s 133A

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).

Survey cases Section 133A Post 01.04.2024
CS 02 Cases Pertaining to Search or Requisition

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).

Search & Seizure Section 132 Section 132A Section 158BA(6)
CS 03 Cases Where Notice u/s 148 Has Been Issued

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.

Section 148 Reassessment NaFAC JAO
CS 04 Cases Related to Registration / Approval Issues

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.

Section 12A/12AB Trusts & NGOs Section 10(23C) ITR-7 Exemption denied
CS 05 Recurring Addition on a Law or Fact Issue in Earlier Year

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.

Recurring issues Transfer Pricing High-value additions Deadline: 15.06.2026
CS 06 Cases Based on Specific Tax-Evasion Information

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.

Tax evasion Intelligence Wing SFT / AIS exclusion Deadline: 15.06.2026

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)

30 June 2026 — Hard Deadline As per the proviso to section 143(2) of the Income-tax Act, 1961, read with section 536(2)(c) of the Income-tax Act, 2025, the time limit for service of notice u/s 143(2) for ITRs filed in FY 2025-26 is 30.06.2026. No scrutiny can be initiated after this date for FY 2025-26 returns.

What This Means for Taxpayers & CAs

📌 Practical Points
  • 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

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