Sec 143(2) reply — SaaS Co.
Draft a reply to a Section 143(2) notice for AY 2024-25 — a Bengaluru SaaS company, ₹38 Cr turnover, no international transactions.
Here's a structured first draft you can adapt:
1. Cover letter
- Acknowledge the DIN and date of notice
- Confirm jurisdiction (faceless assessment, NaFAC)
- Confirm authorised representative under Sec 288
2. Annexures to attach
- Annexure A — ITR vs. audited books reconciliation
- Annexure B — Form 26AS / AIS / TIS mapping with TDS schedule
- Annexure C — Note on revenue recognition under Ind AS 115 (subscription + usage)
- Annexure D — Director KMP remuneration & related-party schedule (Sec 40A(2)(b))
3. Defensive points
- ESOP perquisite valuation method and TDS u/s 192
- Software product vs. royalty characterisation — rely on Engineering Analysis Centre of Excellence (SC, 2021)
- R&D expense allowability under Sec 37(1)
Illustrative draft. Review with the assessee's facts and a qualified CA before filing.
Engineering Analysis Centre of Excellence v. CIT (SC, 2021)CBDT Circular 7/2024Ind AS 115
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