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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

Ashok Kumar Chitlangia, New Delhi vs. ITO Ward-28(1), New Delhi

In the result, the appeal of the assessee for AY 2011-12 is

ITA 3928/DEL/2019[2011-12]Status: DisposedITAT Delhi30 Aug 2023AY 2011-12

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

Section 133(6)Section 143(3)

bearings and is authorized stockists of SKF made bearings having branches at Mumbai, Goa, Rudrapur and Haridwar with Head Office at Delhi. The scrutiny assessments were framed assessment years 2008-09, 2009-10 & 2010-11 u/s 143(3) of the Income Tax Act, 1961 for the assessee

Ashok Kumar Chitlangia, New Delhi vs. ACIT Circle-28(1), New Delhi

In the result, the appeal of the assessee for AY 2011-12 is

ITA 3927/DEL/2019[2010-11]Status: DisposedITAT Delhi30 Aug 2023AY 2010-11

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

Section 133(6)Section 143(3)

bearings and is authorized stockists of SKF made bearings having branches at Mumbai, Goa, Rudrapur and Haridwar with Head Office at Delhi. The scrutiny assessments were framed assessment years 2008-09, 2009-10 & 2010-11 u/s 143(3) of the Income Tax Act, 1961 for the assessee

DCIT, Circle- 1(1), Gurgaon vs. Cinepolis India Pvt. Ltd. (Successor to Fun Multiplex Pvt. Ltd.), Gurgaon

In the result Revenue’s appeal as well as assessee’s cross-objection stand dismissed

ITA 4021/DEL/2018[2014-15]Status: DisposedITAT Delhi30 Aug 2023AY 2014-15

Bench: Shri Kul Bharat & Dr. B.R.R. Kumarassessment Year: 2014-15

Section 143(3)

present appeal are that assessee filed its return of income for A.Y.2014-15 on 29.11.2014 declaring income at Nil. The case was taken up for scrutiny assessment and the AO completed the assessment u/s 143(3) of the Income-tax Act, 1961 (the “Act”) on 30.12.2016 at a total income

M/S M.P. Madhyam, Bhopal vs. The DCIT ( CPC ), Bhopal

In the result, appeals of assessee for A

ITA 426/IND/2022[2017-18]Status: DisposedITAT Indore30 Aug 2023AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11(1)(a)Section 143(1)Section 143(2)Section 143(3)Section 234B

respectively are invalid and liable to be set aside because prior to these orders were passed by the CPC the AO initiated the scrutiny assessment proceedings by issuing notices u/s 143(2) on 21st July 2017 & 9th August 2018 for a.Y.2016-17 and 2017-18 respectively. Thus, the senior counsel ... submitted that when the AO already issued notices u/s 143(2) for these two assessment years and took the return of income for scrutiny assessment then the orders passed by the CPC u/s 143(1) and making adjustment is invalid and liable to be set aside. In support

M/S M.P. Madhyam, Bhopal vs. The DCIT ( CPC ), Bhopal

In the result, appeals of assessee for A

ITA 424/IND/2022[2016-17]Status: DisposedITAT Indore30 Aug 2023AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11(1)(a)Section 143(1)Section 143(2)Section 143(3)Section 234B

respectively are invalid and liable to be set aside because prior to these orders were passed by the CPC the AO initiated the scrutiny assessment proceedings by issuing notices u/s 143(2) on 21st July 2017 & 9th August 2018 for a.Y.2016-17 and 2017-18 respectively. Thus, the senior counsel ... submitted that when the AO already issued notices u/s 143(2) for these two assessment years and took the return of income for scrutiny assessment then the orders passed by the CPC u/s 143(1) and making adjustment is invalid and liable to be set aside. In support

Sarswati Vidhya Pratishthan M.P, Bhupal vs. The ACIT 2(1), Bhopal

In the result, appeal of assessee is allowed

ITA 392/IND/2022[2012-13]Status: DisposedITAT Indore30 Aug 2023AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanisarswati Vidhya Pratishthan Dcit (E) M.P. Bhopal Vs. 01, Harshwardhan Nagar Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Aadas0899M Assessee By Shri Santosh Deshmukh & Shri Parth Jhawar, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 23.08.2023 Date Of Pronouncement 30.08.2023

Section 11Section 11(1)(a)Section 12ASection 143Section 143(3)Section 263

assessee filed its return of income on 26.03.2012 declaring total income at nil after claiming exemption u/s 11 & 12 of the Act. The scrutiny assessment u/s 143(3) was passed on 28.02.2014 at the return income. Thereafter, the assessment order was revised by the CIT(E) vide order dated

Blueprint Infrahomes LLP, Jaipur vs. ADIT CPC Bengaluru Or ITO Ward 6(1) Jaipur, Jaipur

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

ITA 68/JPR/2023[2021-22]Status: DisposedITAT Jaipur30 Aug 2023AY 2021-22

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

For Appellant: Shri Shrawan Kumar Gupta (Adv.)For Respondent: Smt. Monisha Choudhary (Addl. CIT)
Section 143(1)Section 234ASection 801BSection 80I

deduction in a particular section and should not be disallowed u/s 143(1), the deduction if any is to be made only under scrutiny assessment. This is a legal and disputed issue and cannot be taken u/s 143(1). It is the settled legal position of law that

Smt. Trushaba C. Manek L/H. of Late. Shri Chandrasinh P. Manek (Properitor of Dwarkesh Enterprise), Okha, Dist. Jamnagar vs. The Pr. CIT, Jamnagar

In the result, the appeal of the assessee is allowed

ITA 91/RJT/2021[2015-16]Status: DisposedITAT Rajkot29 Aug 2023AY 2015-16

Bench: Mrs. Annapurna Gupta & Mrs. Madhumita Roy(Through Web-Based Video Conferencing Platform) िनधा"रणवष"/Assessment Year: 2015-16 Mrs. Trushaba C. Manek, Vs. Principal Commissioner Of L/H. Of Late Shri Chandrasinh P. Income-Tax, Manek (Prop. Of Dwarkesh Jamnagar Enterprise), Bazar Lane, Raghunath Road, Okha, Gujarat Pan : Aijpm 0949 F अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Dushyant Maharshi, Ar Revenue By : Shri Shramdeep Sinha, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 22.08.2023 घोषणा क" तारीख /Date Of Pronouncement: 29.08.2023 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Learned Principal Commissioner Of Income-Tax, Jamnagar [Hereinafter Referred To As “Pcit”] Dated 30.03.2021, In Exercise Of His Revisionary Powers Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], For The Assessment Year 2015-16. 2. The Assessee Has Raised The Following Grounds:- “1. Hon'Ble Pr. Cit Had Issued Notice U/S. 263 In The Name Of Deceased Person, Therefore Notice Issued U/S. 263 Is Not Valid In The Eyes Of Law & Hence Required To Be Quashed. 2. Hon'Ble Pr. Cit, Jamnagar Has Erred In Law & In Facts In Invoking His Revisionary Powers U/S. 263 Without Having Valid Jurisdiction For Addition Of Income U/S. 2(24)(X) R.W.S. 36(1)(Va) Of The Act For Epf For Rs. 8,35,800/- Whereas Case Was Selected For Limited Scrutiny On The Following Grounds:

For Appellant: Shri Dushyant Maharshi, ARFor Respondent: Shri Shramdeep Sinha, CIT-DR
Section 143(2)Section 143(3)Section 14ASection 2(24)(x)Section 263Section 36(1)(va)

Counsel for the assessee was that that there was no error in the assessment order since the assessment was a limited scrutiny assessment and the error noted by the ld. PCIT was beyond the scope of limited scrutiny of the AO. In this regard, he drew our attention ... notice issued to the assessee, during the assessment proceedings, under Section 143(2) of the Act mentioning that it is a limited scrutiny assessment for examination of the following issues:- a) Contract Receipts/Fees Mismatch b) Sales Turnover Mismatch c) Tax Credit Mismatch 3.1 He further pointed out that the error

Shobhanaben Navinbhai Sorathia, Surat vs. Add./Jt.Deputy/Asst.CIT, NFAC, Delhi

In the result, the appeal of the assessee is allowed

ITA 424/SRT/2023[2012-13]Status: DisposedITAT Surat29 Aug 2023AY 2012-13

Bench: Shri Pawan Singh, Jm & Dr. A.L. Saini, Am आयकर अपील सं./Ita No.424/Srt/2023 (िनधा"रणवष" / Assessment Year: (2012-13) (Virtual Court Hearing) Shobhanaben Navinbhai National Faceless Assessment Sorathia Centre, Delhi / Income Tax Vs. 2-19396-B, Sai Place, B/H Officer, Ward-3(2)(8), Surat Shubh Sankalp Apartment, Kailash Nagar, Sagrampura, Surat-395002 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bdups 1425 F (अपीलाथ" /Appellant) (""थ"/Respondent)

For Appellant: Shri Tinish R Mody, C.AFor Respondent: Shri Vinod Kumar, Sr-DR
Section 142(1)Section 143(2)Section 147Section 148Section 271(1)(b)

note that notice u/s 143(2) is a statutory notice and it is issued by Assessing Officer to get the jurisdiction to make the scrutiny assessment and normally, assessee does not submit the document and papers against such notice. However, against notice u/s 142(1) of the Act the assessee ... submitted the documents and evidence required by the Assessing Officer for scrutiny assessment purposes. We note that third notice u/s 142(1) dated 07.11.2019 was issued to assessee and second notice u/s 142(1) was issued on 14.11.2019 to the assessee. In this connection, we note that earlier two notices

D V Properties Pvt. Ltd., Surat vs. Pr. Commissioner of Income Tax - 1, Surat

In the result, appeal filed by the assessee is partly allowed to the extent indicated above

ITA 121/SRT/2023[2018-19]Status: DisposedITAT Surat29 Aug 2023AY 2018-19

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.121/Srt/2023 Assessment Year: (2018-19) (Physical Hearing) D. V. Properties Pvt. Ltd., Vs. The Pcit - 1, 748-749, Golden Plaza Market, Surat. Ring Road, Surat – 395002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaacd8392B (Appellant) (Respondent) Ms Chaitali Shah, Ca Appellant By Shri Ashok B. Koli, Cit(Dr) Respondent By Date Of Hearing 19/07/2023 Date Of Pronouncement 29/08/2023

Section 143(3)Section 263Section 37(1)Section 43B

case was selected for complete scrutiny under E-Assessment Scheme, 2019, having specific issue of examination as high ratio of refund to TDS. The scrutiny assessment under section 143(3) r.w.s. 143(3A) and 143(3B) of the Act, 1961 was completed on 15.02.2021. 3. Later on, Learned Principal Commissioner

Asst. Commissioner of Income Tax, Circle-2(1)(1), Surat vs. M/S. Priyanshi Textile Private Ltd., Surat

In the result, appeal filed by the Revenue is dismissed

ITA 199/SRT/2022[2013-14]Status: DisposedITAT Surat29 Aug 2023AY 2013-14

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.199/Srt/2022 ("नधा"रणवष" / Assessment Years: (2013-14) (Physical Court Hearing) Assistant Commissioner Of M/S. Priyanshi Textile Pvt.Ltd., Income-Tax, Circle-2(1)(1), C/2, Plot No.74-79, Kim Sayan Vs. Surat, Room No.612, 6Th Floor, Road, Sunrise Interagated Textile Aayakar Bhawan, Near Majura Park, Kareli, Olpad, Surat- Gate, Surat-395001 394540 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaacy 4125 F (अपीलाथ" /Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Assessee By : Shri Mehul Shah, Ca राज" की ओर से/Revenue By : Shri Ashok B. Koli, Cit- Dr सुनवाई क" तार"ख/ Date Of Hearing : 26/07/2023 घोषणा क" तार"ख/Date Of Pronouncement : 29/08/2023 आदेश / O R D E R Per Dr. A. L. Saini: Captioned Appeal Filed By The Revenue, Pertaining To Assessment Year (Ay) 2013-14, Is Directed Against The Order Passed By The National Faceless Appeal Centre, Delhi [Nfac/Ld. Cit(A) For Short] Dated 30.04.2022, Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer, Under Section 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 29.03.2016. 2. Grounds Of Appeal Raised By The Revenue Are As Follows: “(I) On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Deleting The Addition Of Rs.2,72,33,000/- Made By The Assessing Officer On Account Of Unexplained Cash Credit In The Form Of Unsecured Loan U/S 68 Of The Act As The Assessee Has Failed To Prove Bona Fide Of The Transaction Within The Meaning Of Section 68 Of The I.T. Act, 1961. (Ii) On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Deleting The Addition Of Rs.1,08,00,000/- Made By The Assessing Officer On Account Of Unexplained Share Capital & Share Premium U/S 68 Of The Act, Since The Assessee Failed To Prove The Source Of Source.

For Appellant: Shri Mehul Shah, CAFor Respondent: Shri Ashok B. Koli, CIT- DR
Section 142(1)Section 143(3)Section 145(3)Section 68

during remand proceedings also and details of gift were claimed to have been furnished by this individual in his personal scrutiny assessment. It was also stated by the assessee that addition of Rs.85,00,000/- as unexplained gift and Rs.1,17,70,000/- as unexplained unsecured loans were made

Chourangi Builders & Developers Pvt Ltd, Mumbai vs. DCIT-10(1), Mumbai

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

ITA 1282/MUM/2023[2011-12]Status: DisposedITAT Mumbai28 Aug 2023AY 2011-12

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Ms. Vandana SawantFor Respondent: Shri K.C. Selvamani
Section 142(1)Section 143(2)Section 143(3)Section 250Section 271(1)(c)Section 32Section 36(1)(iii)Section 40

various additions made by the AO. Since a considerable amount of time and money has been spent by the Revenue in carrying out the scrutiny assessment followed by the appellate proceedings, therefore, we deem it appropriate to impose a cost of Rs.5,000, on the assessee for its lackadaisical approach

Jawahar Keshari, Patna vs. ITO Department, Patna

In the result, the appeal of the assessee is dismissed

ITA 155/PAT/2023[2017-18]Status: DisposedITAT Patna28 Aug 2023AY 2017-18

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

Section 143(3)Section 263

declaring total income of Rs.3,67,690/-. His case was 1 Assessment Year: 2017-2018 Jawahar Keshasri selected for limited scrutiny assessment and an assessment order was passed on 09.05.2019 under section 143(3). 2. It emerges out from the record that ld. Commissioner took cognizance under section

DCIT Circle-14(2), New Delhi vs. Kortek Electronics (India) Ltd, New Delhi

In the result, the appeal of the revenue is dismissed

ITA 8250/DEL/2019[2010-11]Status: DisposedITAT Delhi28 Aug 2023AY 2010-11

Bench: Sh. N. K. Billaiya & Sh.Kul Bharatassessment Year: 2010-11 Dcit Kortek Electronics Circle -14 (2) Vs (India)Ltd. 133, Vishal New Delhi Tower, District Centre, Janakpuri, New Delhi Pan No.Aabck5593N (Appellant) (Respondent)

Return for the year was electronically filed on 30.09.2010 declaring income of Rs.20,28,59,210/-. The return was selected for scrutiny assessment and accordingly statutory notices were issued and served upon the assessee. 4. While scrutinizing the return the AO found that the assessee has shown GP rate

M/S Parth Developers, Dhar vs. The PCIT -1, Indorer

In the result, appeal of assessee is allowed

ITA 419/IND/2022[2015-16]Status: DisposedITAT Indore28 Aug 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Parth Developers Pr. Cit-1 Manawar Dist. Indore Vs. Dhar (Appellant / Assessee) (Respondent/ Revenue) Pan: Aalfp 4509 N Assessee By Shri Milind Wadhwani, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 22.06.2023 Date Of Pronouncement 28.07.2023

Section 142(1)Section 143Section 143(3)Section 263Section 43C

officers regarding the instruction for limited scrutiny and also expressed its concern about the exceeding of the jurisdiction by the AO in the limited scrutiny assessment. 7. Thus, the Ld. AR has submitted that the case of the assesse was subjected to limited scrutiny to examine the specific issues which ... while passing the assessment order. The issue of applicability of Percentage Completion Method and correctness of the closing stock were not part of the scrutiny assessment proceedings and therefore, the Pr. CIT was not permitted to invoke the provision of section 263 of the Act on the ground that

Assistant Commissioner of Income Tax, Circle- 2(1)(1), Surat vs. Pandesara Green Environment Water Welfare Coop. Society Limited, Surat

In the result, the grounds of appeal raised by the revenue is dismissed

ITA 246/SRT/2023[2020-21]Status: DisposedITAT Surat28 Aug 2023AY 2020-21

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 194A(3)(v)Section 254(1)Section 80PSection 80P(2)(a)Section 80P(2)(d)

They are keeping their funds in cooperative banks and availing deduction of Section 80P(2)(d) of the Act which is allowed in the scrutiny assessment for A.Y. 2012-13 and 2014-15. The assessee also explained the difference in fact with the decision in Totagars cooperative Sale Society

Assistant Commissioner of Income Tax, Circle- 2(1)(1), Surat vs. Pandesara Green Environment Water Welfare Coop. Society Limited, Surat

In the result, the grounds of appeal raised by the revenue is dismissed

ITA 245/SRT/2023[2018-19]Status: DisposedITAT Surat28 Aug 2023AY 2018-19

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 194A(3)(v)Section 254(1)Section 80PSection 80P(2)(a)Section 80P(2)(d)

They are keeping their funds in cooperative banks and availing deduction of Section 80P(2)(d) of the Act which is allowed in the scrutiny assessment for A.Y. 2012-13 and 2014-15. The assessee also explained the difference in fact with the decision in Totagars cooperative Sale Society

Assistant Commissioner of Income Tax, Circle- 2(1)(1), Surat vs. Pandesara Green Environment Water Welfare Coop. Society Limited, Surat

In the result, the grounds of appeal raised by the revenue is dismissed

ITA 244/SRT/2023[2017-18]Status: DisposedITAT Surat28 Aug 2023AY 2017-18

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 194A(3)(v)Section 254(1)Section 80PSection 80P(2)(a)Section 80P(2)(d)

They are keeping their funds in cooperative banks and availing deduction of Section 80P(2)(d) of the Act which is allowed in the scrutiny assessment for A.Y. 2012-13 and 2014-15. The assessee also explained the difference in fact with the decision in Totagars cooperative Sale Society

Shankar Zethabhai Patel, Surat vs. Pr. Commissioner of Income Tax Central, Surat

In the result, appeal of the assessee is allowed

ITA 124/SRT/2022[2018-19]Status: DisposedITAT Surat28 Aug 2023AY 2018-19

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.124/Srt/2022 "नधा"रण वष"/Assessment Year: (2018-19) (Physical Hearing) Shankar Zethabhai Patel, Vs. The Pcit(Central), 505, Sraynik Park Appartment, Rander Surat. Road, Surat – 395009. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Cfepp7235M Appellant By Shri Rasesh Shah, Ca Respondent By Shri Ashok B. Koli, Cit(Dr) 15/06/2023 Date Of Hearing Date Of Pronouncement 28/08/2023

Section 132Section 143(3)Section 263

Individual and has filed return of income for assessment year (AY.) 2018-19 on 28.11.2018, declaring total income of Rs.4,92,920/-. Subsequently, scrutiny assessment was completed under section 143(3) of the Income-Tax Act, 1961 (here in after 'the Act') on 28.12.2019, by the Assessing Officer accepting ... disclosed by the assessee in his return of income, however, the said bank account number was disclosed by the assessee during the scrutiny assessment proceedings before the assessing officer. The assessee has explained each entry of said bank account number before the assessing officer. Therefore, during the assessment stage

Columbus Overseas LLP, 16, Raja Park, Adarsh Nagar, Jaipur vs. Principal Commissioner of Income Tax-1, Jaipur, New Central Revenue Building, Bhagwan Das Road

In the result, appeal of the assessee is dismissed

ITA 196/JPR/2023[2018-19]Status: DisposedITAT Jaipur28 Aug 2023AY 2018-19

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

For Appellant: Shri S.L. Poddar (Adv.)For Respondent: Shri Ajey Malik (CIT) a
Section 142(1)Section 143(2)Section 143(3)Section 263

dated 27.11.2020 along with questionnaire was also issued online and served upon the assessee. The case was selected from complete scrutiny assessment under the E-assessment Scheme, 2019 on the following issues:- 1. Income from Real Estate Business. 2. Contract Receipt or fees 3. Unsecured loans On perusal