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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

Mr. Jobanji Thakor, Ahmedabad vs. The ITO. Ward-3(2)(2), Ahmedabad

Appeal is partly allowed

ITA 264/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad26 Feb 2025AY 2015-16

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं/Ita No.264/Ahd/2019 निर्धारण वर्ष / Assessment Year : 2015-16 Mr. Jobanji Thakor The Ito F-40, Abugiri Society बनाम / Ward-3(2)(2) Tal. Daskroi, Jagatpur V/S. Ahmedabad Ahmedabad - 382 470 स्थायी लेखा सं./Pan: Aknpt 2930 M (अपीलार्थी/ Appellant) (प्रत्यर्थी / Respondent) Assessee By: Shri Mehul K. Patel, Ar Revenue By : Shri A.P. Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing 19/02/2025 घोषणा की तारीख / Date Of Pronouncement: 26/02/2025 आदेश/Order Per Makarand V. Mahadeokar, Am: This Appeal By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals)-3, Ahmedabad [Hereinafter Referred To As “Cit(A)"] Dated 28.12.2018, Confirming The Assessment Order Dated 29.12.2017 Passed By The Assessing Officer [Hereinafter Referred To As “Ao”] Under Section 143(3) Of The Income Tax Act, 1961 [Hereinafter Referred To As "The Act"] For The Assessment Year (Ay) 2015-16.

For Appellant: Shri Mehul K. Patel, ARFor Respondent: Shri A.P. Singh, CIT-DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 2(14)(iii)Section 54B

deduction of Rs.99,00,000/- in his own return of income towards investment in the same agricultural land. The claim was allowed in scrutiny assessment by ITO Ward-3(2)(1), Ahmedabad, vide assessment order dated 30.11.2017. Since the property was already considered for exemption in the brother's assessment

Tropex Suppliers Pvt. Ltd., Kolkata vs. ITO, Ward-4(1), Kolkata.

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

ITA 1231/KOL/2024[2012-13]Status: DisposedITAT Kolkata26 Feb 2025AY 2012-13

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 1231/Kol/2024 Assessment Year: 2012-2013 Tropex Suppliers Private Limited,…………Appellant 113, Netaji Subhash Road, 5Th Floor, Room No. 93, Kolkata-700001 [Pan:Aabct1459N] -Vs.- Income Tax Officer,……………………………....Respondent Ward-4(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069

Section 131Section 142(1)Section 143(2)Section 143(3)

Private Limited Company, who filed its return of income on 24.09.2012 showing total income of Rs.45,184/-. The case was selected for scrutiny assessment through CASS with the reason large share premium received. Accordingly, notice under section 143(2) was issued and served on the assessee-company. Later notice under

Vgm Export, Vasco vs. Joint Commissioner of Income Tax, Margao

ITA 114/PAN/2023[2010-11]Status: DisposedITAT Panaji25 Feb 2025AY 2010-11

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 114/Pan/2023 Assessment Year : 2010-11 Vgm Export Suvarn Bandekar Building, Swatantra Path, Vasco, Goa Pan : Aaafv6197P . . . . . . . Applicant V/S Joint Commissioner Of Income Tax, Margao Range, Margao. . . . . . . . Respondent Appearances Assessee By : Mr P B Deshpande [‘Ld. Ar’] Revenue By : Mr Ravindra Hattalli [‘Ld. Dr’] सुनवाई की तारीख / Date Of Conclusive Hearing : 20/02/2025 घोषणा की तारीख / Date Of Pronouncement : 25/02/2025

For Appellant: Mr P B Deshpande [‘Ld. AR’]For Respondent: Mr Ravindra Hattalli [‘Ld. DR’]
Section 143(1)Section 143(2)Section 143(3)Section 14ASection 250Section 40

same was consistently followed by the appellant in all immediate proceeding & later years which the Revenue accepted in regular scrutiny assessments. Thus, there was no scope for the Revenue to take a swap to treat the same as ‘notional’ now and outdo the aforestated binding judicial precedents. Accordingly, guided precedentially

Income Tax Officer Ward 2(1), Third Floor, Aayakar Bhavan vs. N Kumar Housing and Infrastructure Pvt. Ltd, Seventh Floor

ITA 481/NAG/2024[2020-21]Status: DisposedITAT Nagpur25 Feb 2025AY 2020-21

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Manoj G. MoryaniFor Respondent: Shri Sandipkumar Salunke
Section 28Section 41(1)

that the same was on account of lease deposit and booking advances and further submitted that the same was accepted by the Department in scrutiny assessment for the assessment year 2017-18. The assessee contended that the lease advances of ₹ 10 crore was received from M/s. Poonam Resorts Ltd., prior

ACIT-Central Circle -2(1), Nagpur vs. Shri Nandkumar Khattumal Harchandani, Nagpur

In the result, appeal of the Revenue stands dismissed

ITA 411/NAG/2019[2015-16]Status: DisposedITAT Nagpur25 Feb 2025AY 2015-16

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Manoj G. MoryaniFor Respondent: Shri Sandipkumar Salunke
Section 10(38)Section 68

investment and entire investment were duly accepted by the assessing officer during the previous yer relevant to Asstt. Year 2013-2014 in the scrutiny assessment and assessment were completed U/s. 143(3). The assessee has already submitted copy of assessment order for A.Y. 2013-14 with earlier reply. The assessee

ACIT-Central Circle -2(1), Nagpur vs. Shri Nandkumar Khattumal Harchandani, Nagpur

ITA 410/NAG/2019[2014-15]Status: DisposedITAT Nagpur25 Feb 2025AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Manoj G. MoryaniFor Respondent: Shri Sandipkumar Salunke
Section 10(38)Section 68

investment and entire investment were duly accepted by the assessing officer during the previous yer relevant to Asstt. Year 2013-2014 in the scrutiny assessment and assessment were completed U/s. 143(3). The assessee has already submitted copy of assessment order for A.Y. 2013-14 with earlier reply. The assessee

Kiran Fine Jewellers Private Limited, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-2, Jaipur

In the result ground no 2 raised by the assessee is allowed

ITA 648/JPR/2024[2017-18]Status: DisposedITAT Jaipur25 Feb 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. S. R. Sharma, CA &For Respondent: Sh. P. P. Meena, CIT-Th. V.H
Section 115BSection 143(3)Section 145(3)Section 68Section 69A

Taxmann 423 wherein it was held that where opening stock, sales and closing stock of assessee was accepted during assessment of previous year during scrutiny assessment, receipts made by assessee out of its opening stock, purchases could not be treated as unexplained income to be taxed as income from other

Desh Raj Jakhar, Gordhanpura vs. Income Tax Officer, Ward Neem Ka Thana

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

ITA 1261/JPR/2024[2014-15]Status: DisposedITAT Jaipur25 Feb 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Shaffi Mohd. AdvocateFor Respondent: Mrs. Anita Rinesh, JCIT -DR
Section 147Section 148Section 271(1)Section 5Section 69

Issued notice u/s 148 where the time for notice u/s 143(2) is still available and also the time of regular as well as scrutiny assessment is available upto 30.09.2016 (A) Wrong Facts:- (i) Alleged as ITR not filed but the ITR is filed: The Ld. A.O. has stated ... well as higher authorities and hence is liable to be quashed. (B) Out of Jurisdiction : Action u/s 148 is void where the time for scrutiny assessment is available:- As per the provisions of section 143(2) the Ld. A.O. has power to issue notice and make enquiry about the income

Sbs Biotech Unit II, Sirmour vs. Principal Commissioner of Income Tax-1, Chandigarh

In the result, the appeal of the assessee is allowed

ITA 413/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh25 Feb 2025AY 2017-18

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Ajay Jain, C.AFor Respondent: Shri Abhishek Pal Garg, DR
Section 143(1)Section 143(2)Section 147Section 148Section 263Section 801CSection 80I

revisionary power under section 263." 6 12. It was further submitted that the Courts have consistently held that where the AO during the scrutiny assessment proceeding raised a query which was answered by the assessee to the satisfaction of the AO but the same was not reflected in the assessment ... section 147/151 to the facts of the case: In this case, a return of income was filed for the year under consideration but no scrutiny assessment u/s 143(3) of the Act was made. Accordingly, in this cases, the only requirement to Initiate proceedings u/s 147 is reason to believe

Shree Dhain Auto Logistics Pvt. Ltd., Vadodara vs. The Income Tax Officer, Ward-2(1)(1) (Previously the DCIT- Cicle-2(1)(1)), Vadodara

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

ITA 392/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad25 Feb 2025AY 2015-16

Bench: DR. BRR KUMAR (Vice President), Shri T.R. SENTHIL KUMAR (Judicial Member)

Section 143(3)Section 271DSection 40A(2)(b)Section 43B

assessee filed its Return of Income on 10-09-2015 declaring total income of Rs.68,09,140/-. The case was selected for scrutiny assessment and Assessing Officer disallowed bonus and incentive expenses of Rs.32,00,000/- u/s. 40A(2)(b). The Assessing Officer also made an addition of Rs.32

B Devahie, Chennai vs. ACIT, Central Cir-3(3), Chennai

The appeals stand allowed

ITA 3328/CHNY/2018[2010-11]Status: DisposedITAT Chennai25 Feb 2025AY 2010-11

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं./ Ita No.3327/Chny/2018 (िनधा;रणवष; / Assessment Year: 2009-10) & 2. आयकरअपील सं./ Ita No.3328/Chny/2018 (िनधा;रणवष; / Assessment Year: 2010-11) Late Smt. B. Devahie Acit (Represented By Dr. Balakrishna Central Circle-3(3), बनाम/ Raja – Legal Representative) Chennai. Vs. 9/16, Venkatesan Street, T. Nagar, Chennai-600 014. "थायीलेखासं./जीआइआरसं./Pan/Gir No.Ahupb-6579-N (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Assessee By : Shri K.G. Raghunath (Advocate) - Ld. Ar " थ"कीओरसे/Revenue By : Shri A. Sasikumar (Cit) - Ld. Dr सुनवाई की तारीख/Date Of Hearing : 25-02-2025 घोषणा की तारीख /Date Of Pronouncement : 25-02-2025 आदेश / O R D E R Per Bench:

For Appellant: Shri K.G. Raghunath (Advocate) - Ld. ARFor Respondent: Shri A. Sasikumar (CIT) - Ld. DR
Section 132Section 144Section 153ASection 68

assessee filed return of income on 25-03-2010 admitting income of Rs.1.83 Lacs. The same was apparently subjected to processing only and no scrutiny assessment had happened in the case of the assessee. 3.2 The impugned addition stem from search action u/s 132 on BKR group of cases

B Devahie, Chennai vs. ACIT, Central Cir-3(3), Chennai

The appeals stand allowed

ITA 3327/CHNY/2018[2009-10]Status: DisposedITAT Chennai25 Feb 2025AY 2009-10

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं./ Ita No.3327/Chny/2018 (िनधा;रणवष; / Assessment Year: 2009-10) & 2. आयकरअपील सं./ Ita No.3328/Chny/2018 (िनधा;रणवष; / Assessment Year: 2010-11) Late Smt. B. Devahie Acit (Represented By Dr. Balakrishna Central Circle-3(3), बनाम/ Raja – Legal Representative) Chennai. Vs. 9/16, Venkatesan Street, T. Nagar, Chennai-600 014. "थायीलेखासं./जीआइआरसं./Pan/Gir No.Ahupb-6579-N (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Assessee By : Shri K.G. Raghunath (Advocate) - Ld. Ar " थ"कीओरसे/Revenue By : Shri A. Sasikumar (Cit) - Ld. Dr सुनवाई की तारीख/Date Of Hearing : 25-02-2025 घोषणा की तारीख /Date Of Pronouncement : 25-02-2025 आदेश / O R D E R Per Bench:

For Appellant: Shri K.G. Raghunath (Advocate) - Ld. ARFor Respondent: Shri A. Sasikumar (CIT) - Ld. DR
Section 132Section 144Section 153ASection 68

assessee filed return of income on 25-03-2010 admitting income of Rs.1.83 Lacs. The same was apparently subjected to processing only and no scrutiny assessment had happened in the case of the assessee. 3.2 The impugned addition stem from search action u/s 132 on BKR group of cases

Gheverchand Rikhabchand Jain, Mumbai vs. ACIT, Circle 4(2)(1), Mumbai

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

ITA 6619/MUM/2024[2014-15]Status: DisposedITAT Mumbai25 Feb 2025AY 2014-15

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Dharan Gandhi – AdvocateFor Respondent: Shri Dr. Kishor Dhule, CIT D/R
Section 234ASection 234BSection 250Section 68

that the assessee is a trader in shares and securities, partner in firms and has income from investment. During the course of the scrutiny assessment proceedings, I.T.A. No. 6619 /Mum/2024 3 the AO noticed that there were several loan creditors and the assessee was asked to prove the identity

Shri Kishore Mohanlal Dingra, Mumbai vs. DCIT, Cir-41(1)(1), Mumbai

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

ITA 2258/MUM/2024[2018-19]Status: DisposedITAT Mumbai25 Feb 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2018-19 Shri Kishore Mohanlal Dingra, Dy. Cit Circle 41(1)(1), 105, Dosti Ambrosia S.M. Road, Kautilya Bhavan, Room No. Kb/614, Vs. Mumbai-400037. Bandra Kurla Complex, Bandra (East), Mumbai-400051. Pan No. Atxpd 4896 P Appellant Respondent

For Appellant: Mr. Nimesh TharFor Respondent: 24/02/2025
Section 234ASection 234BSection 234CSection 56(2)(x)Section 69A

adjudication. 3. Briefly stated, facts of the case a Briefly stated, facts of the case are that in the scrutiny re that in the scrutiny assessment completed u/s 143(3) of the Income completed u/s 143(3) of the Income-tax Act, 1961 (in tax Act, 1961 (in short

DCIT, New Delhi vs. M/S. Sohna Technobuild Pvt. Ltd., New Delhi

Appeal is dismissed

ITA 6381/DEL/2015[2010-11]Status: DisposedITAT Delhi25 Feb 2025AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 10(1)Section 153A

action disallowing/adding the assessee’s claim of section 10(1) exemption of his agricultural income amounting to Rs.2.28 lakhs, in the course of scrutiny assessment framed on 27.12.2016 u/s 153A r.w.s. 143(3) of the Act, a perusal of the instant case file indicates that the departmental authorities had carried

Sigma Convertors, Chennai vs. Assistant Commissioner of Income Tax, Circle, Parwanoo

In the result, the appeal of the assessee is allowed

ITA 997/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh24 Feb 2025AY 2012-13

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

For Appellant: Shri Amar Pratap Singh, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl.CIT, Sr.DR
Section 143(3)

that assessee has filed its return of income on 27.08.2012 declaring total income of Rs.17,27,58,289/-. Its case was selected for scrutiny assessment and ultimately an assessment order under Section 143(3) of the Income Tax Act was passed on 27.02.2015. The AO has accepted the returned income ... reasons about this failure of the assessee rather a composite transaction was there whose details were disclosed in the scrutiny assessment and the AO has accepted the amount to the extent received or accrued to the assessee but did not taxed the amount lying in an ‘Escrow Account

Mahakali Developers and Resorts Private Limited, Scf vs. PCIT Patiala, Aaykar Bhawan

Appeals of the assessee are allowed

ITA 295/CHANDI/2024[2015-2016]Status: DisposedITAT Chandigarh24 Feb 2025AY 2015-2016

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

For Appellant: Shri Ashok Goel, CAFor Respondent: Smt. Kusum Bansal, CIT, DR
Section 139(1)Section 143(2)Section 143(3)Section 144Section 147Section 24Section 24(1)Section 263

under Section 139(1) of the Income Tax Act for assessment years 2013-14 and 2015-16. Both these years were selected for scrutiny assessments by issuance of a notice under Section 143(2). The assessments have been framed on 03.03.2016 and 10.08.2017. 3.1 The AO has reopened the assessments

Mahakali Developers and Resorts Private Limites, Scf, Ist Floor vs. PCIT Patiala, Aaykar Bhawan Patiala

Appeals of the assessee are allowed

ITA 294/CHANDI/2024[2013-2014]Status: DisposedITAT Chandigarh24 Feb 2025AY 2013-2014
For Appellant: Shri Ashok Goel, CAFor Respondent: Smt. Kusum Bansal, CIT, DR
Section 139(1)Section 143(2)Section 143(3)Section 144Section 147Section 24Section 24(1)Section 263

under Section 139(1) of the Income Tax Act for assessment years 2013-14 and 2015-16. Both these years were selected for scrutiny assessments by issuance of a notice under Section 143(2). The assessments have been framed on 03.03.2016 and 10.08.2017. 3.1 The AO has reopened the assessments

Dy. Commissioner of Income Tax, Circle-1(1), Hyderabad vs. Mamta Jain, Hyderabad

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

ITA 250/HYD/2024[2016-17]Status: DisposedITAT Hyderabad24 Feb 2025AY 2016-17

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: : Dr. Sachin Kumar, SR-DR
Section 143(3)Section 147Section 148

after verifying such documents, the Ld. CIT(A) arrived at the findings. Further, in A.Y. 2017-18 i.e. in the very next year, in scrutiny assessment, the Ld. AO did not raise any such objection related to the discounting business of the assessee and passed the order under section

DCIT, Middletonton Row vs. Bishnupur Public Education Institute, Bishnupur

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

ITA 1021/KOL/2023[2016-17]Status: DisposedITAT Kolkata24 Feb 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Bishnupur Public Education Institute Dcit 10B, Middleton Row, 5 Th Floor, Gopeswarpalli, Bishnupur, Vs. Kolkata-700071, West Bengal Bankura-722122, West Bengal (Appellant) (Respondent) Pan No. Aabtb4176D Assessee By : S/Shri S.M. Surana & Sunil Surana & Dipak Kumar, Ars Revenue By : Shri Subhendu Datta, Dr Date Of Hearing: 03.02.2025 Date Of Pronouncement : 24.02.2025

For Appellant: S/Shri S.M. Surana &For Respondent: Shri Subhendu Datta, DR
Section 11Section 11(2)Section 12ASection 13(9)Section 139Section 139(1)Section 139(4)

assessment proceedings, or before in appellate authority, however, we notice that in the instant case, the case of the assessee was not selected for scrutiny assessment and it was mere processing of return by the computer with the set program. Had it been the case of scrutiny proceeding