Perspectives from our practice.

Why only half automation of scrutiny notices will pile up the pending litigation.

The CBDT has collected ₹16,083 crore through targeted communications — with no notice, no assessment order and no right of appeal. Case selection is automated, but the officer's screen has no field for the taxpayer's explanation, so approval becomes the path of least resistance. What that asymmetry costs, who pays for it, and four changes that would close the gap.