“scrutiny assessment”

Assessment ProceduresSection 143(3)Section 143(3)7,671 judgments

KAILAS KALYAN CREATORS PRIVATE LIMITED,AHMEDABAD vs. ITO WARD 2(1)(1), AHMEDABAD, AHMEDABAD

ITA 2342/AHD/2025[2023-24]Status: DisposedITAT Ahmedabad09 Apr 2026AY 2023-24

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.2342/Ahd/2025 िनधा"रण वष" /Assessment Year : 2023-24 Kailas Kalyan Creators The Ito बनाम/ Private Limited Ward-2(1)(1) V/S. 5, Prerna Kutir Bungalows Ahmedabad – 380 051 Nr. Sarthi Hotel Vastrapur, Bodakdev Ahmedabad – 380 054 "थायी लेखा सं./Pan: Aaack 9110 C (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee By : Shri Chetan Agarwal, A.R. Revenue By : Shri Alpesh Parmar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 24/02/2026 घोषणा की तारीख /Date Of Pronouncement: 09/04/2026 आदेश/O R D E R Per Sanjay Garg:

For Appellant: Shri Chetan Agarwal, A.RFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 250Section 48

filed its return of income for the year under consideration, i.e. 2023- 24 on 30/10/2023. The case of the assessee was taken up for scrutiny assessment for the reason, “Low Long Term Capital Gain and high improvement cost”. 3.1. During the assessment proceedings, the Assessing Officer (AO) observed that ... issue relating to disallowance of loss of Rs.2,57,516/- is concerned, we find that this issue neither was a subject matter of scrutiny assessment nor the loss claimed has been disputed by the AO. It seems to be a matter of only clerical error as the AO noted

ITO WARD - 52(5), NEW DELHI vs. INDERPAL SINGH L/H OF LATE SHRI RAGHBIR SINGH, NEW DELHI

In the result, the appeal filed by the Department of Revenue is allowed

ITA 1165/DEL/2020[2009-10]Status: DisposedITAT Delhi09 Apr 2026AY 2009-10

Section 139Section 142(1)Section 143(1)Section 147Section 148Section 151Section 250Section 68

declaring total income of Rs.21,14,570/-. The return was processed u/s 143(1) of the act. The case was not selected for scrutiny assessment for the year under consideration. A letter dated 23.03.2016 was received in the office of the ACIT, Circle-52(1), Delhi from ITO Ward

H R MOTORS,HIMATNAGAR vs. DEPUTY COMMISSIONER OF INCOME TAX, AHMEDABAD

In the result, the appeal filed by the Assessee is hereby allowed

ITA 1764/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2017-18

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(3)Section 68

assessee filed its Return of Income on 30-10-2017 declaring total income of Rs.70,69,170/-. The return was taken for scrutiny assessment, since the assessee had received cash advance from 611 customers amounting to Rs.1,57,76,639/- on 08-11-2016 being announcement of demonetization of Rs.500

ARHAM ANMOL PROJECTS PRIVATE LIMITED,VILLAGE VALSHIND, BHIWANDI vs. CIRCLE 1 KALYAN, KALYAN, THANE

In the result, the legal grounds challenging the validity of the assessment are dismissed

ITA 5011/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Mar 2026AY 2019-20

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokararham Anmol Projects Dcit Circle 1, Private Limited 2Nd Floor, Rani H. No. 1113, Ground Vs. Mansion, Murbad Floor, Arham Logiparc, Road, Kalyan Nh-3, Nashik Highway, (West), Thane, Village Valshind, Maharashtra – 421 Bhiwandi, Maharashtra – 301 421 302. Pan/Gir No. Aagca9644P (Applicant) (Respondent) Assessee By Shri Subhash Bains, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 28.01.2026 Date Of Pronouncement 26.03.2026

Section 144Section 144BSection 147Section 148Section 194CSection 194ISection 234FSection 250

assessment. It was contended that issuance of notice under section 143(2) is a sine qua non for assuming jurisdiction to proceed with scrutiny assessment and such notice must be validly issued by the Assessing Officer competent to carry the assessment to its logical conclusion. 12. The learned AR submitted ... required that where a return is filed, issuance of notice under section 143(2) is mandatory if the Assessing Officer seeks to proceed with scrutiny assessment. The jurisprudence has consistently held that absence of such notice is fatal. However, there has never been a statutory requirement that the very same

DCIT-4(1), INDORE, INDORE vs. ODDIVILLE FOODS AND FROZEN, INDORE

Accordingly, the grounds raised by the Revenue are dismissed\nand the order of the Ld

ITA 427/IND/2025[2018-19]Status: DisposedITAT Indore20 Mar 2026AY 2018-19

Section 115JSection 143(3)Section 263Section 35ASection 80

return so filed, the\nassessee claimed deduction of Rs.8,60,92,248/- u/s 35AD.\nThe case of assessee was subjected to scrutiny-assessment and the\nAO passed assessment order dated 04.02.2021 u/s 143(3) by\naccepting the loss / total income declared by assessee without any\nvariation. The AO allowed deduction ... complete scrutiny as evident from\nassessment order itself, where in first para itself it has been specifically\nmentioned that case was selected for Complete scrutiny assessment.\nPage 5 of 16\nOddiville Foods and Frozen\nITA No. 427/Ind/2025 – AY 2018-19\nAlthough this is the fact that initial issue on which

VCOMMISSION MEDIA PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE 26(1), NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 4071/DEL/2024[2015-16]Status: DisposedITAT Delhi20 Mar 2026AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2015-16 V Commission Media Private Acit, Circle-26(1), Room No.195A, 1St Floor, Limited, F-342, Regus Level 4, Rectangle Vs C.R Building, One D4, Saket, New Delhi-110002 New Delhi-110017 Pan-Aaecv0198B Assessee Revenue Assessee By Shri Pulkit Saini, Adv. Revenue By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 07.01.2026 Date Of Pronouncement 20.03.2026

Section 139Section 143(3)Section 40ASection 40A(2)(a)

Page 2 of 9 relevant AY on 30.09.2015 at the total income of Rs.3,72,56,170. The case of assessee was selected for scrutiny assessment. The assessment of the same was completed under section 143(3) on 22.12.2017 at an income of Rs. 5,84,61,653 after making

AMAZON SMART COMMERCE SOLUTIONS PRIVATE LIMITED,DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1, DELHI

In the result, grounds raised by the assessee are dismissed

ITA 3533/DEL/2025[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22

Section 143(1)Section 143(3)Section 263Section 40A(2)

income (ROI) on 13.03.2022 for relevant AY 2021-22 declaring a total income of INR 291,00,11,321. The ROI was selected for scrutiny assessment and vide order dated 15.12.2022, the returned income was accepted as such by the NaFAC\n20. In the impugned revisionary proceedings, the PCIT sought

KONDA SEENIVASAIYER DAMODHARAN KISHORI LAL,MADURAI vs. DCIT, NCC-2, , MADURAI

In the result, the appeal filed by the assessee is allowed

ITA 3873/CHNY/2025[2017-18]Status: DisposedITAT Chennai17 Mar 2026AY 2017-18

Bench: SHRI S.S. VISWANETHRA RAVI (Judicial Member), SHRI S. R. RAGHUNATHA (Accountant Member)

For Appellant: Mr. B. Ramakrishnan, F.C.AFor Respondent: Ms. Gouthami Manivasagam

Section 143(2)Section 143(3)Section 271BSection 44A

before the ld.CIT(A) and delete the penalty as the assessee had already filed the audit report before even issuing notice u/s.143(2) for scrutiny assessment. Further, the ld.AR relied on the decision of the coordinate bench of Chennai Tribunal in the case of Vellakovil Primary Agricultural Cooperative Bank

NIDEC MOBILITY INDIA PRIVATE LIMITED,GURGAON, INDIA vs. COMMISSIONER OF INCOME-TAX (APPEAL), CENTRAL NER, GUWAHATI, GUWAHATI

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 3616/DEL/2025[2018-19]Status: DisposedITAT Delhi17 Mar 2026AY 2018-19

Bench: SHRI RAMIT KOCHAR (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

For Appellant: Sh. Sourav Aggarwal, CAFor Respondent: Sh. S.K. Jadhav, CIT-DR

Section 143(1)Section 143(2)Section 143(3)Section 144BSection 144CSection 92C

case of the assessee was selected by Revenue for framing scrutiny assessment through CASS. Statutory notices u/s 143(2) and 142(1) were issued by the AO during assessment proceedings. The assessee participated in the assessment proceedings . The AO observed that the assessee was incorporated in India with the purpose ... under normal provisions of the Act. The case of the assessee was selected by Revenue for framing scrutiny assessment through CASS. The assessee participated in the assessment proceedings . The assessee is engaged in trading of automotive car body control module and key less entry system for cars manufactured in India

CHHABI LATA SAHU,ROURKELA vs. INCOME TAX OFFICER, WARD-4, ROURKELA

In the result, the appeal of the assessee is allowed

ITA 626/CTK/2025[2009-10]Status: DisposedITAT Cuttack16 Mar 2026AY 2009-10

Bench: Shri George Mathan & Shri Rajesh Kumarassessment Year: 2009-10 Chhabi Lata Sahu Ito, Ward-4, Rourkela

For Appellant: Shri S. K. Sarangi & Bishwa Jyoti Pattnaik, ARsFor Respondent: Shri Shakeer Ahamed, Sr. DR

Section 143Section 148

based on any new material. 4 10. The law in relation to the reopening of the assessment, particularly after the original assessment was a scrutiny assessment under Section 143 (3) of the IT Act, has been explained in detail in a number of decisions of the Supreme Court of India

MITTAL RICE & GENERAL INDUSTRIES,AMBALA CITY vs. INCOME TAX OFFICER WARD 4 AMBALA , AMABALA CANT

In the result, appeal of the assessee is allowed

ITA 1421/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh16 Mar 2026AY 2017-18

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 1421/Chd/2025 "नधा"रण वष" / Assessment Year: 2017-18 Mittal Rice & General Industries, The Ito, Hissar Road, Ambala City. Vs Ward – 4, Ambala. "थायी लेखा सं./Pan No: Aadfm9229N अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ajay Jain, Ca Revenue By : Dr. Ranjit Kaur, Addl. Cit, Sr. Dr Date Of Hearing : 17.02.2026 Date Of Pronouncement : 16.03.2026

For Appellant: Shri Ajay Jain, CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 143(2)

facts of the case are that assessee has filed its return of income electronically on 31.03.2017. The case of the assessee was selected for scrutiny assessment by issuance of a notice u/s 143(2) on 26.09.2018. The AO has observed that during the demonetization period, a sum of Rs.72 lacs

INCOME TAX OFFICER WARD 6 (1), MOHALI vs. SKYCITY BUILDERS AND PROMOTERS PRIVATE LIMITED, KHRAR PUNJAB

In the result, the corresponding grounds as raised by the revenue stand dismissed

ITA 1217/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh16 Mar 2026AY 2012-13

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1066/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Skycity Builders & Promoters Pvt. Ltd. Dcit Ward 6(1) बनाम/ Room No.3, 1St Floor Sco-90, City Heart Kharar-Chandigarh Road, Livestock Complex Vs. Kharar, Rupnagar (Punjab) - 140301 Sector – 68, Mohali -160062 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं./ Ita No.1217/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit Ward 6(1) M/S Skycity Builders & Promoters Pvt. Ltd. बनाम/ Room No.3, 1St Floor Sco-90, City Heart Livestock Complex Kharar-Chandigarh Road, Vs. Sector – 68, Mohali -160062 Kharar, Rupnagar (Punjab) - 140301 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Yamini (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.03.2026

For Appellant: Sh. Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Ms. Yamini (CIT) - Ld. DR (Virtual)

Section 143(3)Section 148Section 68

offered original return of income. The Ld. AO noted that though the assessee had filed return of income on 05-10-2013, but no scrutiny assessment was done for the year. The property in question was stated to be purchased out of unsecured loans. The Ld. AO proceeded to examine ... para-1 has stated that “As per ITD database, the assessee has not filed any return of income for the year under consideration. No scrutiny assessment u/s 143(3) has taken place in the case of the assessee for the relevant year”. In para-3 also, it has been recorded

SKYCITY BUILDERS AND PROMOTERS PRIVATE LIMITED, ,KHARAR, RUPNAGAR vs. DCIT WARD 6(1), CHANDIGARH JAO ITO 6(1) MOHALI, CHANDIGARH

In the result, the corresponding grounds as raised by the revenue stand dismissed

ITA 1066/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh16 Mar 2026AY 2012-13

For Appellant: Sh. Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Ms. Yamini (CIT) - Ld. DR (Virtual)

Section 143(3)Section 148Section 68

RASNA PRIVATE LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-3(1)(1), AHMEDABAD

In the result the Ground Nos

ITA 926/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad16 Mar 2026AY 2017-18

Bench: The Addl. Cit(A) Who Has Confirmed The Addition Made By The Ao, Thereby Dismissed The Assessee’S Appeal.

Section 143(3)Section 14ASection 36(1)Section 38

return of income for Asst. Year 2017-18 on 28.10.2017 declaring total income of Rs.3,12,22,940/-. The case was selected for scrutiny assessment and made following disallowances: (a) Disallowance u/s.14A read with Rule 8D of Rs.33,81,941/- (b) Late payment of PF and ESIC of Rs.16

RAGHANI TRADELINK,AHMEDABAD vs. INCOME TAX OFFICER, WARD 1(3)(1), AHMEDABAD, GUJARAT

In the result, the appeal of the assessee stands allowed

ITA 1692/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad16 Mar 2026AY 2020-21

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.1692/Ahd/2025 िनधा"रण वष" /Assessment Year : 2020-21 Raghani Tradelink The Income Tax Officer बनाम/ B-239, 2Nd Floor, Ward-1(3)(1) V/S. Sumeel Business Park-3 Ahmedabad Sarangpur B/H. New Cloth Market Ahmedabad – 380 002 "थायी लेखा सं./Pan: Aavfr 9778 D (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee By : Shri Sunil Surana, Ar Revenue By : Shri Abhijit, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 08/01/2026 घोषणा की तारीख /Date Of Pronouncement: 16/03/2026 आदेश/O R D E R Per Sanjay Garg:

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Abhijit, Sr.DR

Section 142(1)Section 143(2)Section 250

sellers. The assessee filed its return of income on 15/02/2021 declaring an income of Rs.91,74,530/-. The case was selected for Complete Scrutiny Assessment under CASS for the issue regarding Business expenses including large Commission expenses and showing low net profit. 4.1. During the assessment proceedings, in response ... been consistently following the aforesaid business module for the last three years since its incorporation, however, the AO observed that there was no scrutiny assessment in earlier years and comparison of expenses cannot be made with previous years. He, though accepting that the assessee- firm had made business expenses during

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. SHRI DEEPAK MOHANLAL PURSWANI, RAJKOT

ITA 665/RJT/2024[2022-23]Status: DisposedITAT Rajkot13 Mar 2026AY 2022-23

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. SR. DR

Section 143(3)Section 147Section 250

leads to\nhigh-pitched assessment.\n1. CBDT vide Instruction No. 225/101/1021-ITA-II dated 23.04.2022 had modified the\nearlier instructions in the case of high-pitched scrutiny assessment where CBDT has\nacknowledged the fact of such high-pitched assessment and for that purpose,\nconstituting of local committee to deal with such assessment

ASHOKKUMAR PRABHULAL MEHTA,SURAT vs. ITO, WARD-1(3)(1), SURAT

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1303/SRT/2025[2013-14]Status: DisposedITAT Surat13 Mar 2026AY 2013-14

Bench: Ld. Add. Cit(A) Who Has Given Four Opportunities Of Hearing Between 13.01.2021 To 06.10.2025. The Assessee Neither Responded To The Notices & Nor Sought For Adjournments, Thereby, The Appeal Was Dismissed Ex-Parte.

Section 143(3)Section 54B

declaring total income of Rs.4,37,919/- and agriculture income of Rs.7,51,070/-. The return was taken for scrutiny assessment, wherein sale of land and computation of capital gain was not accepted and determined the Long Term Capital Gain (‘LTCG’) of Rs.30,38,526/-. Similarly, claim of reinvestment

NATHAN ANIL RAO, MUMBAI vs. THE ITO -CIRCLE 23(1), MUMBAI

In the result, appeal of the assessee is allowed for statistical

ITA 8666/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Mar 2026AY 2017-18

Bench: Shri Om Prakash Kant (Account Member) & Ms. Kavitha Rajagopal () Assessment Year: 2017-18

For Appellant: Shri Vijaykumar Soni, CIT DRFor Respondent: Shri Nikhil Tiwari

Section 143(2)Section 68Section 69

Scrutiny Income Tax Act which was the beyond the scope of Limited Scrutiny Income Tax Act which was the beyond the scope of Limited Scrutiny assessment under sectio assessment under section 143(2) of the Income Tax Act which was on account n 143(2) of the Income ... examine the worth of this company in course of submitted before the AO to examine the worth of this company in course of scrutiny assessment. 4 Nathan Anil Rao It is observed despite av It is observed despite availing ample/ multiple opportunity in assessment stage ailing ample/ multiple opportunity

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(2)(1), MUMBAI, MUMBAI vs. BLEND FINANCIAL SERVICES LIMITED, MUMBAI

In the result, appeal of the R

ITA 8088/MUM/2025[2018-19]Status: DisposedITAT Mumbai13 Mar 2026AY 2018-19

Bench: Shri Om Prakash Kant (Account Member) & Ms. Kavitha Rajagopal () Assessment Year: 2018-19

For Appellant: Shri Rajesh SanghviFor Respondent: Shri Swapnil Choudhari (SR. DR)

Section 143(3)Section 37Section 40A(2)(b)

assumption of 10% increase salary, though it was not a 18 on the assumption of 10% increase salary, though it was not a scrutiny assessment. The AO has disregarded the actual salary of Asst t. The AO has disregarded the actual salary of Asst t. The AO has disregarded ... related parties had been accepted in scrutiny directors and related parties had been accepted in scrutiny directors and related parties had been accepted in scrutiny assessments for the immediately p assessments for the immediately preceding assessment years. In receding assessment years. In the absence of any material change in facts

SUJATA PRAKASH JAWALE,MUMBAI vs. ITO WARD 42(3)(4), MUMBAI

In the result, the appeal filed by the assessee stands allowed

ITA 7572/MUM/2025[2014-15]Status: DisposedITAT Mumbai13 Mar 2026AY 2014-15

Bench: Smt. Beena Pillai ()

Section 143(2)Section 147Section 56(2)(vii)

will not be applicable. 5.4. It is further noted from the records placed before this Tribunal that the co-owners were also subjected to scrutiny assessment wherein the Ld. AO has accepted the position as submitted by the assessee before this Tribunal on identical facts and evidences. The assessment order

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