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“scrutiny assessment”

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

The decision most relied on for scrutiny assessment is CIT v. Sunbeam Auto Ltd. (332 ITR 167), cited in 897 judgments on BharatTax.

Leading authorities on scrutiny assessment

CIT v. Sunbeam Auto Ltd.
332 ITR 167 · 2011 · High Court
897
citing judgments

The Commissioner cannot revise an assessment under Section 263 merely because the assessment order does not explicitly reflect an inquiry, or because the Commissioner holds a different opinion. An inquiry, even if considered inadequate, or an assessment based on a plausible view by the Assessing Officer after due examination, does not automatically make the order erroneous or prejudicial to the interests of the revenue.

Phool Chand Bajrang Lal v. ITO
203 ITR 456 · 1993 · Supreme Court
396
citing judgments

Reassessment proceedings under Section 147 are valid even after a scrutiny assessment under Section 143(3), provided the Assessing Officer forms a reason to believe, based on definite, specific, and reliable information, that income escaped assessment due to the assessee's failure to fully and truly disclose material facts.

Sanjay Bimalchand Jain v. PCIT-1, Nagpur
89 Taxmann.com 196 · 2018 · High Court
251
citing judgments

The exemption for long-term capital gains on share transactions is unavailable if the assessee fails to discharge the onus of proving the genuineness of gains arising from dubious share transactions designed to convert unaccounted income into tax-exempt capital gains. Courts will uphold an assessment based on the Revenue's evidence of price rigging or penny stock manipulation if the assessee cannot provide cogent evidence for the abnormal rise in share value.

CIT v. British Paints India Ltd.
188 ITR 44 · 1991 · Supreme Court
204
citing judgments

The Assessing Officer has a duty to examine whether an assessee's books of account truly disclose the correct income and is not bound to accept the accounting system regularly employed by the assessee or methods followed in earlier years. Each assessment year is a distinct and self-contained unit for tax purposes.

Principal Commissioner of Income-tax v. Subodh Agarwal
149 Taxmann.com 373 · 2023 · High Court
194
citing judgments

Approval of draft assessment orders under Section 153D must be granted with due application of mind, not mechanically. Approving multiple cases, such as 38 in a single day, without proper scrutiny amounts to mechanical approval, rendering the assessment invalid.

ITO v. TechSpan India (P) Ltd.
92 Taxmann.com 361 · 2018 · Supreme Court
194
citing judgments

Reassessment under Section 147/148 is invalid if it constitutes a mere change of opinion by the Assessing Officer without any fresh tangible material, especially after the assessee made a full and truthful disclosure during the original scrutiny assessment under Section 143(3).

Narayanappa v. CIT
63 ITR 219 · 1967 · Supreme Court
187
citing judgments

The approval required from a higher authority under section 153D of the Income Tax Act is an administrative act, not a quasi-judicial one. Consequently, an opportunity of hearing is not required to be given to the assessee at the stage of obtaining such approval, provided the approving authority is competent.

CIT v. Ralson Industries Ltd. 5
288 ITR 322 · 2007 · Supreme Court
153
citing judgments

The Supreme Court affirmed that lower authorities are bound by decisions of higher authorities due to judicial discipline. It also clarified that the Commissioner, in exercising revisional power under Section 263, can conduct necessary inquiries to determine if an assessment is prejudicial to the Revenue.

Judgments citing scrutiny assessment

Ces Limited, Hyderabad vs. DCIT., Circle-1(1), Hyderabad

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 638/HYD/2025[2018-19]Status: DisposedITAT Hyderabad06 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.638/Hyd/2025 Assessment Year 2018-2019 Ces Limited, The Dcit, Circle-1(1), Hyderabad – 500 032. Vs. Hyderabad. Telangana. Telangana. Pan Aadcs4564P (Appellant) (Respondent) निर्धारिती द्वधिध/Assessee By : Ca P Murali Mohan Rao िधजस् व द्वधिध/Revenue By : Dr. Sachin Kumar, Sr. Ar सुिवधई की तधिीख/Date Of Hearing: 02.02.2026 घोषणध की तधिीख/Pronouncement: 06.02.2026 आदेश/Order Per Vijay Pal Rao:

For Appellant: CA P Murali Mohan RaoFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 139Section 143Section 143(1)Section 143(2)Section 143(3)Section 250Section 36(1)(va)

rival contentions of the parties and perused the material available on record. Admittedly, the AO has examined the case of the assessee under scrutiny assessment for two limited issues i.e., for expenditure of personal nature and refund claim. The AO is duty bound to restrict to the claim ... assessee unless he after taking the approval from the competent authority made the limited scrutiny assessment to full-fledged assessment. That has not been done, therefore, AO was duty bound to restrict to its findings only to the issue under consideration before him. Admittedly, no addition has been made

Sumanth Badiga, Hyderabad vs. DCIT., Circle - 5(1), Hyderabad

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 628/HYD/2025[2020-21]Status: DisposedITAT Hyderabad06 Feb 2026AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.628/Hyd/2025 Assessment Year 2020-2021 Sumanth Badiga, The Dcit, Circle-5(1), Hyderabad – 500 004. Vs. Hyderabad. Telangana. Telangana. Pan Ahqpb8508F (Appellant) (Respondent) निर्धारिती द्वधिध/Assessee By : Ca C S Subrahmanyam & Sri V. Siva Kumar, Advocate िधजस् व द्वधिध/Revenue By : Sri Lv Bhaskara Reddy, Cit-Dr सुिवधई की तधिीख/Date Of Hearing: 02.02.2026 घोषणध की तधिीख/Pronouncement: 06.02.2026 आदेश/Order Per Vijay Pal Rao:

For Appellant: CA C S Subrahmanyam and Sri V. Siva Kumar, AdvocateFor Respondent: Sri LV Bhaskara Reddy, CIT-DR
Section 143(3)Section 263Section 54Section 54F

tune of Rs.1,00,92,000/-. The case of the assessee was selected to complete scrutiny under CASS. The Assessing Officer passed the scrutiny assessment u/sec.143(3) r.w.s.144B of the Act vide order dated 02.09.2022 accepting the returned income of the assessee. Thereafter, on perusal of the record ... ITA.No.1164/Mad./2012 dated 04.07.2013. 4.1. The learned Authorised Representative of the Assessee has submitted that the Assessing Officer conducted the enquiry during the scrutiny assessment by issuing show cause notice u/sec.142(1) of the Act which was duly replied by the assessee by furnishing relevant details and evidence. Therefore

Aditya Birla Sun Life Amc Limited, Maharashtra vs. The Deputy Commissioner of Income Tax- Circle 6(1)(1), Maharashtra

ITA 6703/MUM/2025[2023-24]Status: DisposedITAT Mumbai06 Feb 2026AY 2023-24

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar1. Ita No. 6663/Mum/2025 (Assessment Year: 2017-18) 2. Ita No. 6701/Mum/2025 (Assessment Year: 2018-19) 3. Ita No. 6702/Mum/2025 (Assessment Year: 2022-23) & 4. Ita No. 6703/Mum/2025 (Assessment Year: 2023-24) Aditya Birla Sun Life Dcitcircle-6(1)(1), Amc Limited, Room No. 502, 5Th 17Th Floor, One World Vs. Floor, Aayakar Centre Tower-1, Jupiter Bhavan, M. K. Mill Compount, 841, Road, Churchgate, Senapati Bapat Marg, Mumbai-400 020 Delisle Road, S.O. Mumbai-400 013 Pan/Gir No. Aaacb6134D (Applicant) (Respondent) Assessee By Shri Ronak Doshi, Shri Shrey Agrawal & Shri Aadish Jain, Ld. Ars Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 27.01.2026 Date Of Pronouncement 06.02.2026

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 270ASection 36(1)(va)Section 40Section 43B

section 143(1) while completing the assessment under section 143(3), without considering the assessee’s detailed submissions on merits.  It was contended that scrutiny assessment proceedings under section 143(3) are independent of the intimation (33) ITA No. 6663, 6701, 6702 & 6703 /Mum/2025 Aditya Birla Sun Life AMC Limited ... intimation under section 143(1) with an assessment order under section 143(3), unless the issue has been examined and adjudicated in the scrutiny assessment. (34) ITA No. 6663, 6701, 6702 & 6703 /Mum/2025 Aditya Birla Sun Life AMC Limited  Reliance was placed on the decision of the Bangalore Bench