← All Phrases

“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

Vijay Kumar, Samastipur vs. ITO, Ward 3 (3), Samastipur

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

ITA 79/PAT/2025[2017-18]Status: DisposedITAT Patna09 Jan 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.79/Pat/2025 Assessment Year: 2017-18 Vijay Kumar………..………….………………. …………………....Appellant Kishanpur Warish Nagar, Samastipur, Bihar-848101. [Pan: Aqcpk3836C] Vs. Ito, Ward-3(3), Samastipur…....……………..………………….…..... Respondent Appearances By: Shri G. P. Tulsiyan, Fca, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 08, 2026 Date Of Pronouncing The Order : January 09, 2026 आदेश / Order Per Sonjoy Sarma: The Present Appeal Filed By The Assessee Is Directed Against The Order Dated 29.01.2025 Passed By The Nfac, Delhi U/S 250 Of The Income Tax Act, 1961 (The ‘Act’) For The Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee, An Individual, Filed His Return Of Income For The Assessment Year 2017–18 Declaring A Total Income Of ₹3,51,040. Subsequently, The Case Of The Assessee Was Selected For Scrutiny Assessment & Notice Under Section 143(2) Of The Income-Tax Act, 1961 Was Duly Issued. During The Course Of Assessment Proceedings, The Assessing Officer Noticed Cash Deposits Of ₹20,00,000 In The Assessee’S Bank Account. The Assessing Officer Provided Several

Section 143(2)Section 143(3)Section 250Section 69A

income for the assessment year 2017–18 declaring a total income of ₹3,51,040. Subsequently, the case of the assessee was selected for scrutiny assessment, and notice under section 143(2) of the Income-tax Act, 1961 was duly issued. During the course of assessment proceedings, the Assessing Officer

Srirangarao Nadipallly, Karimnagar vs. ACIT., Circle-1, Karimnagar

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

ITA 844/HYD/2025[2016-17]Status: DisposedITAT Hyderabad09 Jan 2026AY 2016-17

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.844/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Shri Srirangarao Nadipally Vs. Assistant Commissioner Karimnagar Of Income Tax Pan:Acbpn3816E Circle-1, Karimnagar (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Adv. Kvssn Kumar राज" व "ारा/Revenue By: Sankar Pandi P - Sr. Dr सुनवाई की तारीख/Date Of Hearing: 05/01/2026 घोषणा की तारीख/Pronouncement: 09/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Srirangarao Nadipally (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 24.03.2025 For The A.Y 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Adv. KVSSN KumarFor Respondent: Sankar Pandi P - Sr. DR
Section 143(2)Section 143(3)

been disclosed in the return of income for AY 2015–16 and the same has been accepted by the Ld. AO in scrutiny assessment without any adverse remark, the opening cash balance for the year under consideration cannot be doubted and the addition made by the Ld. AO deserves ... doubting the opening cash balance, which stood accepted in the Page 8 of 14 ITA No 844 of 2025 Srirangarao Nadipally scrutiny assessment of the earlier year. Accordingly, the addition of Rs.91,22,287/- is liable to be deleted. 10. The Ld. AR submitted that the second issue arising from

Kp Advisory Services LLP, Hyderabad vs. ACIT., Central Circle-2(1), Hyderabad

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

ITA 1013/HYD/2025[2018-19]Status: DisposedITAT Hyderabad09 Jan 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1013/Hyd/2025 Assessment Year 2018-2019 Kp Advisory Services Llp, The Acit, Hyderabad. Pin–500 016. Vs. Central Circle-2(1), Telangana. Hyderabad. Pan Aarfk7349F (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Sp Chidambaram, Advocate राज" व "ारा /Revenue By: Sri Ashutosh Pradhan, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 10.12.2025 घोषणा की तारीख/Pronouncement: 09.01.2026 आदेश/Order

For Appellant: Sri SP Chidambaram, AdvocateFor Respondent: Sri Ashutosh Pradhan, Sr. AR
Section 10(34)Section 143(1)Section 143(3)Section 14ASection 234ASection 270A

declared in the return of income as well as considered by the CPC are not in dispute. We further note that in the scrutiny assessment u/sec.143(3) of the Act, the Assessing Officer has also considered the said income of Rs.69,48,001/- as exempt income in Paras ... hence, there is no requirement of filing a separate appeal against the Order of CPC u/sec.143(1) as it merges with the scrutiny assessment Order passed by the Assessing Officer u/sec.143(3) of the Act. Grounds of appeal no.2 of the assessee are allowed. 8. Ground no.3 of assessee