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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

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 vs. Shri Deepak Mohanlal Purswani, Rajkot

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

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.630 & 631/Rjt/2024 निर्धारण वर्ष / Assessment Year: (2021-2022 & 2022-23) Hybrid Hearing Shree Deepak Mohanlal Puruswani बनाम The Dcit, Cc-1 Rajkot Nr. Maa Krupa, 4- Saurashtra Kala Vs. Aaykar Bhawan "Amruta Estate", Kendra Society, Opp. Nirmala Convent, Mg Road, Rajkot 360001, Kalawad Road, Rajkot-360001 (अपीलार्थी/Appellant) स्थायीलेखासं/. जीआइआरसं/.Pan No. : Ajvpp5139P (प्रत्यर्थी/Respondent) आयकर अपील सं/. Ita No.665/Rjt/2024 निर्धारण वर्ष / Assessment Year: (2022-23) The Dcit, Cc-1 Rajkot बनाम Shree Deepak Mohanlal Puruswani Aaykar Bhawan“Amruta Estate", 2Nd Vs. Nr. Maa Krupa, 4- Saurashtra Kala Floor Mg Road Kendra Society, Opp. Nirmala Rajkot 360001, Gujrat Convent, Kalawad Road, (अपीलार्थी/Appellant) स्थायीलेखासं/. जीआइआरसं/.Pan No. : Ajvpp5139P Rajkot-360001 (प्रत्यर्थी/Respondent) निर्धारितीकीओरसे/Assessee By : Shri Mehul Ranpura, Ld. Ar राजस्वकीओरसे/Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाईकीतारीख / Date Of Hearing : 16/01/2026 घोषणाकीतारीख /Date Of Pronouncement : 13/03/2026 आदेश/Order Per, Bench: Captioned Appeals Filed By The Assessee & Revenue, Pertaining To

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. SR. DR
Section 143(3)Section 147Section 250

leads to high-pitched assessment. 1. CBDT vide Instruction No. 225/101/1021-ITA-II dated 23.04.2022 had modified the earlier instructions in the case of high-pitched scrutiny assessment where CBDT has acknowledged the fact of such high-pitched assessment and for that purpose, constituting of local committee to deal with such assessment