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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

Educo Ventures Pvt. Ltd., Kolkata vs. D.C.I.T., Central Circle - 1(4), Kolkata

Appeal is dismissed

ITA 2025/KOL/2024[2020-2021]Status: DisposedITAT Kolkata18 Dec 2025AY 2020-2021

Bench: the AO.

Section 133ASection 147Section 250Section 68

Furthermore, scrutiny assessment in the cases of the appellant has been conducted u/s.143(3) of the Act on regular basis. The A.O. had conducted enquiries and examined all the details including financial capacity of these lender companies in the earlier assessments and no adverse views were taken ... details of the scrutiny assessment for A.Y. 2012-13 to A.Y. 2014-15 is given in the submission of the appellant are as under: The assessee assessment for the following years were also completed u/s 143(3) of the Income Tax Act, 1961 as under: Asst. Year Order u/s Date

Educo Ventures Pvt. Ltd., Kolkata vs. D.C.I.T., Central Circle - 1(4), Kolkata

Appeal is dismissed

ITA 2024/KOL/2024[2015-2016]Status: DisposedITAT Kolkata18 Dec 2025AY 2015-2016

Bench: the AO.

Section 133ASection 147Section 250Section 68

Furthermore, scrutiny assessment in the cases of the appellant has been conducted u/s.143(3) of the Act on regular basis. The A.O. had conducted enquiries and examined all the details including financial capacity of these lender companies in the earlier assessments and no adverse views were taken ... details of the scrutiny assessment for A.Y. 2012-13 to A.Y. 2014-15 is given in the submission of the appellant are as under: The assessee assessment for the following years were also completed u/s 143(3) of the Income Tax Act, 1961 as under: Asst. Year Order u/s Date

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Subramaniam Kathiresan, Chennai

In the result, appeal filed by the Revenue for AY 2014-15 is dismissed

ITA 899/CHNY/2025[2014-15]Status: DisposedITAT Chennai18 Dec 2025AY 2014-15

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. N. Arjun Raj, Advocate &For Respondent: Ms. Gauthami Manivasagam
Section 132Section 153Section 153ASection 153A(1)Section 153C

case where the searched assessee's assessments are completed u/s. 143(3) or 148 or 153A/153C of the Act or if the mandatory scrutiny assessment notices u/s. 143(2) of the Act has become time barred], then those assessment years to be treated as un-abated assessment and by virtue

M/S. City Union Bank Ltd., Kumbakonam vs. PCIT, Madurai

In the result, the appeal for A

ITA 1126/CHNY/2024[2018-19]Status: DisposedITAT Chennai18 Dec 2025AY 2018-19

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Shri. S. Ananthan, F.C.A. &For Respondent: Shri. Bipin C.N., CIT
Section 115JSection 142(1)Section 143(2)Section 143(3)Section 14ASection 17(2)Section 263Section 36(1)(vii)Section 36(1)(viia)

under the provisions of section 115JB of Income Tax Act, 1961 (the Act). A notice u/s.143(2) of the Act was issued for scrutiny assessment on 22.09.2019 and notices u/s.142(1) of the Act were issued on various dates calling for details and documents in support of various claims made ... ld.PCIT has invoked jurisdiction u/s.263 of the Act erroneously in contravention of the said provision. In the present case, the AO during the scrutiny assessment proceedings had called for the specific details in respect of all the issues dealt by the impugned order of the Ld. PCIT, by issuing notice

Dusters Total Solutions Services Private Limited, Bangalore vs. DCIT, Circle-2(1)(2), Bangalore

In the result appeal of the assessee is hereby allowed

ITA 980/BANG/2025[2018-19]Status: DisposedITAT Bangalore18 Dec 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Kavita Jha, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT (DR)
Section 143(3)Section 80J

year under consideration, the assessee claimed deduction under section 80JJAA of the Act for Rs. 14,81,19,175/-. The return was selected for scrutiny assessment under section 143(3) of the Act. 4. During the assessment proceedings, the AO observed that the claim of the assessee under section 80JJAA

Dusters Total Solutions Services Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

In the result appeal of the assessee is hereby allowed

ITA 653/BANG/2025[2020-21]Status: DisposedITAT Bangalore18 Dec 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Kavita Jha, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT (DR)
Section 143(3)Section 80J

year under consideration, the assessee claimed deduction under section 80JJAA of the Act for Rs. 14,81,19,175/-. The return was selected for scrutiny assessment under section 143(3) of the Act. 4. During the assessment proceedings, the AO observed that the claim of the assessee under section 80JJAA

Dusters Total Solutions Services Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

ITA 652/BANG/2025[2018-19]Status: DisposedITAT Bangalore18 Dec 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Respondent: Smt. Kavita Jha, Advocate
Section 143(3)Section 80J

year under consideration, the assessee claimed deduction under section 80JJAA of the Act for Rs.14,81,19,175/-. The return was selected for scrutiny assessment under section 143(3) of the Act. 4. During the assessment proceedings, the AO observed that the claim of the assessee under section 80JJAA

Assistant Commissioner of Income Tax (Exemption) Circle-1, Bengaluru vs. Cosmopolis Educational Trust, Bengaluru

In the result, the appeal filed by the Revenue is hereby dismissed

ITA 575/BANG/2023[2021-22]Status: DisposedITAT Bangalore18 Dec 2025AY 2021-22

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2021-22

For Appellant: Shri Madhusudhan UA, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT
Section 11

find any infirmity in this. 26. The assessee also pointed out that in the immediately following year (A.Y. 2022-23), in the scrutiny assessment under section 143(3) r.w.s. 144B of the Act, the Revenue accepted similar heads of expenditure. While each year is separate, this consistency, coupled with

Sanjay Ahuja, New Delhi vs. Commissioner of Income Tax, Delhi

Appeal of the assessee is allowed

ITA 860/DEL/2024[2017-18]Status: DisposedITAT Delhi18 Dec 2025AY 2017-18

Bench: Shri Vikas Awasthyआअसं.860/धिल्ली/2024 (नि.व. 2017-18) Sanjay Ahuja, 196, Top Floor, Mig Green Flats, Rajouri Garden, Delhi 110027 ...... अपीलार्थी/Appellant Pan: Adrpa-8279-R बिाम Vs. Commissioner Of Income Tax, ..... प्रनिवादी/Respondent Nfac, Delhi अपीलार्थी द्वारा/Appellant By : Shri Shivam Garg, Advocate (Through Vc) प्रधििािीद्वारा/Respondent By : Shri Keshav Kishore Aanad, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 18/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 18/12/2025 आदेश/Order Per Vikas Awasthy, Jm:

For Appellant: Shri Shivam Garg, Advocate (Through VC)For Respondent: Shri Keshav Kishore Aanad, Sr. DR
Section 68Section 68A

short ‘the CIT(A)’] dated 09.01.2024, for Assessment Year 2017-18. 2. Shri Shivam Garg, appearing on behalf of the assessee submitted that in scrutiny assessment proceedings for AY 2017-18, the Assessing Officer (AO) inter alia made addition of Rs.6,00,000/- u/s.68A of the Income

R. M. Commercial Pvt. Ltd., (Earlier Known As Citrine Merchants Private Limited), Kolkata vs. DCIT, Circle 5(1), Kolkata

In the result, the appeal filed by the assessee is allowed

ITA 2114/KOL/2025[2017-2018]Status: DisposedITAT Kolkata17 Dec 2025AY 2017-2018

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2017-18 R. M Commercial Pvt. Ltd (Citrine Merchants Pvt. Ltd.).……..………………….……….……….……Appellant 113, Netaji Subhash Road, 2Nd Floor, Dalhousie, Kolkata - 1. [Pan: Aabcc3113A] Vs. Dcit, Circle-5(1), Kolkata………….…………………….....……...…..…..Respondent Appearances By: Shri Manoj Kataruka, Adv., Appeared On Behalf Of The Appellant. Shri S B Chakraborthy, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 19, 2025 Date Of Pronouncing The Order : December 17, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 11.09.2025 Of The Addl/Jcit(A), Panaji [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2017–18. 2. Brief Facts Of The Case Are That The Assessee Is A Domestic Company & Had Filed Its E-Return For Ay 2017-18 On 26-10-2017 Declaring A Total Income Of Rs.2,68,77,750/-. The Case Was Selected For Complete Scrutiny Assessment Under Cass & Notices Were Issued U/S 143(2) & 142(1) Of The Act, Against Which The Assessee Filed All The Details Along With Books Of Accounts. The Assessing Officer Completed The Assessment Of The Assessee U/S 143(3) Vide Order Dated 18-12-2019 On A Total Income Of Rs.2,79,27,779/- By Making An Addition Of Rs.10,50,029/- U/S 14A R.W.R 8D. R. M Commercial Pvt. Ltd 3. Being Aggrieved By The Said Order, The Assessee Filed An Appeal Before The Ld. Cit(A) & The Ld. Cit(A) Confirmed The Order Of The Assessing Officer.

Section 143(2)Section 143(3)Section 14ASection 250

return for AY 2017-18 on 26-10-2017 declaring a total income of Rs.2,68,77,750/-. The case was selected for complete scrutiny assessment under CASS and notices were issued u/s 143(2) and 142(1) of the Act, against which the assessee filed all the details along

Basant Properties Limited, Kolkata vs. A.C.I.T., Circle - 5(1), Kolkata

In the result, the appeal filed by the assessee is allowed

ITA 1765/KOL/2025[2017-2018]Status: DisposedITAT Kolkata17 Dec 2025AY 2017-2018

Bench: Shri Rajesh Kumar (Accountant Member), Shri Pradip Kumar Choubey (Judicial Member)

Section 14ASection 250

income for the assessment year 2017-18 electronically on 28.10.2017 declaring loss of Rs. 18,89,620/-. The said return was selected for scrutiny assessment under CASS. During the assessment proceedings, the Assessing Officer found that the assessee had earned total dividend income, which did not form part of total

Vama International, Mumbai vs. ACIT 22(3), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5456/MUM/2025[2012-13]Status: DisposedITAT Mumbai17 Dec 2025AY 2012-13

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Dharan Gandhi, ARFor Respondent: Ms. Kavitha Kaushik, (Sr. DR)
Section 143(1)Section 147Section 148

income for the relevant assessment year declaring total income at Rs.45,58,688/-which was processed u/s.143(1) of the Act. No regular scrutiny assessment was done. However, the case was selected for scrutiny u/s 147 of the Act in consequence of the search and survey action was conducted ... assessment year. Moreover, the materials on which reopening has been initiated and concluded are the same which had already been subject matter of earlier scrutiny assessment proceedings and the addition made treating the said purchases as bogus had already been decided by the ITAT in favour of the assessee. Therefore

Neelkanth Realtors Limited, Mumbai vs. Income Tax Officer, Ward 3(2)(3), Mumbai

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

ITA 5206/MUM/2025[2017-2018]Status: DisposedITAT Mumbai17 Dec 2025AY 2017-2018

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2017-18 Neelkanth Realtors Limited, Income Tax Officer, 508, Dalamal House, Ward-3(2)(3), J.B. Marg, Vs. Maharshi Karve Road, Nariman Point, New Marinelines, Mumbai-400021. Mumbai-400020. Pan : Aaaca9796N (Appellant) (Respondent) For Assessee : Shri Pratik A. Mehta For Revenue : Shri Brajendra Kumar, Sr.Dr Date Of Hearing : 03-12-2025 Date Of Pronouncement : 17-12-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 31-07-2025, Pertaining To Assessment Year (Ay) 2017-18. 2. Briefly Stated, Facts Of The Case Are That The Assessee Filed Its Return Of Income Declaring Total Income Of Rs. 10,71,080/-, Which Was Selected For Scrutiny & Notices U/S. 143(2) & 142(1) Of The Income Tax Act, 1961 („The Act‟) Were Issued. In Response, The Assessee Filed Its Submissions From Time To Time, Thereafter The Assessment Order Was Passed By The Ao

For Appellant: Shri Pratik A. MehtaFor Respondent: Shri Brajendra Kumar, Sr.DR
Section 143(2)Section 143(3)Section 14A

interest free funds and interest thereon has been capitalized as part of work-in- progress and the same has been allowed and accepted in scrutiny assessment proceedings for the earlier assessment years. There is however no cognizance of the submissions so filed by the assessee and the assessment proceedings thereafter

Mulchand Shamji Chheda HUF, Mumbai vs. Income Tax Officer -26(2)(3), Mumbai

In the result, the appeal of the assessee is dismissed

ITA 1700/MUM/2025[2016-17]Status: DisposedITAT Mumbai17 Dec 2025AY 2016-17

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 143(3)Section 194ASection 271BSection 40Section 44A

ought to have deducted the TDS on interest. The ld.AR. emphatically stressed on the point that in the past, in all the scrutiny assessments, AO had accepted the interest income as income from Other Sources as disclosed in the computation of income. Thus, mere change in the opinion in this

Uma Strips Limited, Delhi vs. ACIT, Circle-27(1), Delhi

In the result, appeal of the assessee in ITA No

ITA 2507/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Dec 2025AY 2017-18

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: Shri Neeraj Mangla, CAFor Respondent: Ms. Pooja Swaroop, CIT- DR
Section 115BSection 133(6)Section 142(1)Section 143(2)Section 143(3)Section 68

Income Tax Department. Thereafter notices u/s 142(1) alongwith detailed questionnaire were sent to the assessee. 5. The Assessing Office, during the course of scrutiny assessment proceedings, noticed that the assessee had taken unsecured loan amounting to Rs. 17,99,05,000/- from two parties namely M/s Kay Ess Enterprises

Brawny Nivesh P.Ltd, New Delhi vs. ACIT, Central Circle-13, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 571/DEL/2019[2015-16]Status: DisposedITAT Delhi17 Dec 2025AY 2015-16

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singh

Section 143Section 143(3)Section 3Section 47Section 56Section 56(2)(via)Section 56(2)(viia)

Income Tax Return was e-filed by the assessee on24/09/2015 vide acknowledgement No. 815747901240915 showing total income ofRs.7,587/-. The case was selected for scrutiny assessment through CASS under the category "Limited Scrutiny" and accordingly notice u/s.143 (2) of the I.T. Act, 1961 was issued on 21/04/2016 and duly served ... facie, are convincing. When the AO had not held the sundry debtors of Rs.29,35,130/- existing as on 31.03.2014 as bogus/fictitious in the scrutiny assessment order of the AY 2014-15 even after questioning the same cannot be held as bogus/fictitious in subsequent order of the relevant year

Gujarat Vaibhav Publications Pvt. Ltd., Ahmedabad vs. The ITO, Ward-2(1)(1), Ahmedabad

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

ITA 1359/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

Section 143(3)Section 147Section 148Section 234ASection 271(1)(c)Section 37

this case, 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 case the only requirement to initiate proceedings u/s.147 is reason to believe which has been recorded above. 5. It is pertinent to mention here

Gujarat Vaibhav Publications Pvt. Ltd., Ahmedabad vs. The ITO, Ward-2(1)(1), Ahmedabad

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

ITA 1358/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2015-16

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

Section 143(3)Section 147Section 148Section 234ASection 271(1)(c)Section 37

this case, 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 case the only requirement to initiate proceedings u/s.147 is reason to believe which has been recorded above. 5. It is pertinent to mention here

Deputy Commissioner of Income Tax, Circle 2(1)(1), Vadodara, Race Course Cirlce vs. Epigral Limited, Narmada

In the result, the appeal filed by the Revenue is hereby dismissed

ITA 1206/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2011-12

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 143(1)Section 143(3)

Income declaring total loss of Rs.34,26,57,814/-. The return was processed u/s. 143(1) on 27- 01-2012 and then selected for scrutiny assessment. 2.1. On verification of the profit & loss account, the Assessing Officer noticed that the assessee has debited Rs. 1,88,37,071/- on account

Torrent Power Grid Limited, Ahmedabad vs. The Pr.CIT-3, Ahmedabad

In the result, the appeal filed by the assessee is hereby allowed

ITA 1191/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2020-21

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 142(1)Section 143(3)Section 144BSection 263Section 80G

assessee is engaged in the business of transmission of electricity filed its original Return of Income declaring income of Rs.2,04,97,280/-. Regular scrutiny assessment I.T.A.No.1191/Ahd/2025 2 A.Y. 2020-21 Page No Torrent Power Grid Ltd. vs. PCIT was completed on 09-09-2022 accepting the returned income