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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

M.K. Wood Trading Corporation, Lucknow vs. DCIT/ACIT-1, Lucknow

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

ITA 504/LKW/2025[2020-21]Status: DisposedITAT Lucknow31 Dec 2025AY 2020-21

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2020-21 M. K. Wood Trading Corporation V. The Dcit/Acit-1 10, Basha Khera Lucknow New Takrohi, Indira Nagar Lucknow (U.P) Tan/Pan:Aarfm2443G (Applicant) (Respondent) Applicant By: Shri Rakesh Garg, Advocate Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 07.08.2024, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2020-21. 2.0 The Brief Facts Of The Case Are That The Assessee Was A Partnership Firm Engaged In The Business Of Timber Products. The Assessee Filed Its Return Of Income For The Year Under Consideration On 10.12.2020 Declaring A Total Income Of Rs.54,030/-. The Case Of The Assessee Was Selected For Scrutiny Assessment And, Accordingly, The Assessing Officer (Ao) Issued Statutory Notices To The Assessee. However, There Was No Response From The Side Of The Assessee. The Ao Finally Issued Show Cause Notice Under Section 144 Of The Income Tax Act, 1961 (Hereinafter Called “The Act’) Dated 21.3.2022, Vide Which The Ao

For Respondent: Shri R.R.N. Shukla, D.R
Section 143(3)Section 144Section 144BSection 68

income for the year under consideration on 10.12.2020 declaring a total income of Rs.54,030/-. The case of the assessee was selected for scrutiny assessment and, accordingly, the Assessing Officer (AO) issued statutory notices to the assessee. However, there was no response from the side of the assessee

Insight Print Communications Private Limited, Mumbai vs. The PCIT, Mumbai-4, Mumbai

In the result, appeal of the assessee is dismissed

ITA 3384/MUM/2025[2020-21]Status: DisposedITAT Mumbai31 Dec 2025AY 2020-21

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2020-21 Insight Print Communications Pcit, Mumbai-4 Private Limited A-14, Synthofine Industrial Estate, Behind Virvani Industrial Estate, Vs. Dindoshi, Off Aarey Road, Goregaon (East), Mumbai – 400063 (Pan: Aabci6530P) (Appellant) (Respondent) Present For: Assessee : Shri Lalchand Choudhary, Ca Revenue : Shri R.A. Dhyani, Cit Dr Date Of Hearing : 08.10.2025 Date Of Pronouncement : 31.12.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Revisionary Order By Ld. Pcit, Mumbai-4, Vide Order No. Itba/Rev/F/Rev5/2024- 25/1074740466(1), Dated 20.03.2025 Passed U/S. 263 Of The Income- Tax Act, 1961 (Hereinafter Referred To As The “Act”) Against The Assessment Order By Assessment Unit, U/S. 143(3) R.W.S.144B Of The Act, Dated 22.09.2022, For Ay 2020-21. 2. Grounds Taken By Assessee Are Reproduced As Under: 1. The Appellant Prefers The Following Appeal Against The Order Dated 20/03/2025 Of The Principal Commissioner Of Income Tax, Mumbai-4 (Hereinafter Referred To As "The Pcit ") Passed Under Section 263 Of The Income Tax Act, 1961 ("The Act"). Each Of The Grounds Is In Alternative & Without Prejudice To Other.

For Appellant: Shri Lalchand Choudhary, CAFor Respondent: Shri R.A. Dhyani, CIT DR
Section 142(1)Section 143(3)Section 263Section 37Section 40

revisionary proceedings u/s. 263 is on an issue which was within the jurisdiction of the Assessing Officer, being part of scope under limited scrutiny assessment. Reliance placed by the assessee on the decision of Co- ordinate Bench in the case of Fineotex Chemical Ltd. vs PCIT in ITA No. 3458/Mum/2025 ... hold good as the issue raised by the ld. PCIT is the one which was within the scope of ld. AO while undertaking limited scrutiny assessment. 5.2. On the jurisdictional issue raised by the assessee that Assessment Unit (AU) is not covered within the definition of Assessing Officer