CHIRAG CHINUBHAI PATEL,AHMEDABAD vs. THE ITO, WARD-3(2)(6), AHMEDABAD

ITA 451/AHD/2026Status: DisposedITAT Ahmedabad27 April 2026AY 2017-183 pages
AI SummaryAllowed

What were the facts?

The assessee's case was selected for Limited Scrutiny for specific reasons related to capital gains and cash deposits. The Assessing Officer made an addition beyond the scope of this Limited Scrutiny.

What did the Tribunal hold?

The Tribunal held that the Assessing Officer cannot travel beyond the scope of Limited Scrutiny unless the case is converted to Complete Scrutiny. Since the addition was made outside the defined scope, the appeal was allowed.

What were the issues?

Whether additions made by the Assessing Officer were beyond the permissible scope of Limited Scrutiny. Whether the lower authorities erred in confirming additions and invoking Section 115BE.

Which sections of the Income-tax Act were involved?

Section 68,Section 115BE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC” BENCH, AHMEDABAD

For Appellant: Shri Parin Shah, AR
For Respondent: Shri Saresa Kartik Laxmanbhai, Sr. DR
Hearing: 15.04.2026Pronounced: 27.04.2026

PER DR. B.R.R. KUMAR, VICE-PRESIDENT:

- This appeal is filed by the Assessee against the appellate order dated 08.09.2025 passed by the National Faceless Appeal Centre(NFAC), Delhi, relating to the Assessment Year 2017-18. The assessee has raised the following grounds of appeal:

2.1.

The order passed by lower authorities is bad in law and required o be quashed.

2.

The JCIT(A) erred in law and on facts in confirming addition of Rs.2,06,426/- u/s.68 of the Act ignoring submission of the appellant.

3.

The order passed by lower authorities is required to be quashed as case has been taken for scrutiny for “Limited Scrutiny” Asst. Year : 2017-18 - 2– whereas AO travelled beyond same without conversion of “Limited Scrutiny” to “Complete Scrutiny”.

4.

Ld.JCIT

The order continues below.

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