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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

Rajesh Mohan Singh Hajari, Mumbai vs. ITO Ward 16(3)(1), Mumbai

In the result, ground No. 3 of assessee‟s appeal is allowed

ITA 5157/MUM/2025[2014-15]Status: DisposedITAT Mumbai10 Dec 2025AY 2014-15

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2014-15 Rajesh Mohan Singh Hajari, Income Tax Officer, Type 4 B/293, Ward-16(3)(1), Dr. Bam Hosp., Vs. Aayakar Bhavan, Byculla, Mumbai-400020. Mumbai-400030. Pan : Aazph4367E (Appellant) (Respondent) For Assessee : Shri Shailesh Bandi For Revenue : Shri Kavan N. Limbasiya, Sr.Dr Date Of Hearing : 03-12-2025 Date Of Pronouncement : 10-12-2025 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 21-07-2025, Pertaining To Assessment Year (Ay) 2014-15, Wherein The Assessee Has Taken The Following Grounds Of Appeal: “1. On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Grossly Erred In Confirming The Action Of The Ao Of Reopening The Case Under Section 148 Of The It Act, 1961. 2. On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Grossly Erred In Confirming The Action Of The Ao, The Reassessment Order

For Appellant: Shri Shailesh BandiFor Respondent: Shri Kavan N. Limbasiya, Sr.DR
Section 142(1)Section 143(3)Section 147Section 148

case are that the assessee has filed his original return of income on 28-11-2014, which was the subject matter of scrutiny assessment u/s. 143(3) of the Income Tax Act, 1961 („the Act‟), wherein the returned income was accepted vide order dt. 21-10-2016. Subsequently, basis information

Outsystems Singapore Pte. Ltd., Singapore vs. DCIT Circle 2(2)(2) (International Taxation), New Delhi

In the result, appeal of the assessee is allowed

ITA 1601/DEL/2025[2022-23]Status: DisposedITAT Delhi10 Dec 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं.1601/धिल्ली/2025(नि.व. 2022-23) Outsytems Singapore Pte. Ltd., 41-01, 8 Temasek Boulevard, Suntec Tower Three, ...... अपीलार्थी/Appellant Singapore 389980 Pan Aadco-0528-P बिाम Vs. The Deputy Commissioner Of Income Tax, Circle International Tax 2(2)(2), Civic Centre, ..... प्रनिवादी/Respondent Minto Road, New Delhi 110002 अपीलार्थी द्वारा/ Appellant By : Shri Ajit Jain & Ms. Shivangi Chitlangia Chartered Accountants प्रधिवािीद्वारा/Respondent By : Ms. Ekta Jain, Cit(Dr) सुिवाई की निथर्थ/ Date Of Hearing : 03/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 10/12/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act,1961 (Hereinafter Referred To As ‘The Act’) Dated 10.01.2025, For Assessment Year 2022-23. 2. The Assessee In Appeal Has Raised As Many As 13 Grounds. The Ld. Counsel For The Assessee At The Outset Submitted That He Is Not Pressing Ground No. 4 Of Appeal Assailing Validity Of The Assessment Order Without Din. In Light Of The 2 Statement Made By Ld. Counsel For The Assessee, Ground No. 4 Of Appeal Is Dismissed As Not Pressed.

For Appellant: Shri Ajit Jain & Ms. Shivangi ChitlangiaFor Respondent: Ms. Ekta Jain, CIT(DR)
Section 14Section 143(3)

notice(s) for conduct of assessment proceedings electronically, it is hereby directed that except for search related assessments, proceedings in other pending scrutiny assessment cases shall be conducted only through the 'E-Proceeding' functionality in ITBA/E-filing. However, in cases where the concerned assessee objects to conduct of assessment proceedings electronically ... particular manner, the same are binding on the Department. The AO is thus mandatorily required to sign the assessment order digitally where the scrutiny assessments are conducted electronically. Since, in the instant case the assessment has been made under ‘E’- Proceedings and assessment order has been signed manually, the same

Anmol Himanshu Patel Legal Heir of Late Himanshu Raojibhai Patel, Vadodara vs. The ITO, Ward-1(1)(4) Now Present Jurisdiction the Dy.CIT, Circle-1(1)(1), Vadodara

In the result, the appeal of the assessee stands allowed

ITA 1479/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2015-16

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.1479/Ahd/2025 िनधा"रण वष" /Assessment Year : 2015-16 Anmol Himanshu Patel The Ito बनाम/ (Legal Heir Of Late Himanshu Ward-1(1)(4) V/S. Raojibhai Patel) Now Present Jurisdiction Bs/B-7, Indraprasth Complex The Dy.Cit, Circle-1(1)(1) Nr. Inox Race Course Circle Vadodara – 390 007 Vadodara – 390 007 "थायी लेखा सं./Pan: Acqpp 6460 P (अपीलाथ'/ Appellant) (!( यथ'/ Respondent) Assessee By : Shri Biren Shah, Ar Revenue By : Shri B.P. Srivastava, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 18/09/2025 घोषणा की तारीख /Date Of Pronouncement: 09/12/2025 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 10/06/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2015-2016. 2. The Assessee, In This Appeal, Has Raised The Following Grounds Of Appeal: Anmol Himanshu Patel (Legal Heir Of Late Himanshu Raojibhai Patel) Vs. Dcit Asst.Year 2015-16. “1. In Law & In The Facts & Circumstances Of The Case Of The Appellant, The Order Passed By The Cit(A) U/S 250 Of The Act Is Bad In Law & Deserves To Be Quashed.

For Appellant: Shri Biren Shah, ARFor Respondent: Shri B.P. Srivastava, Sr.DR
Section 2(22)(e)Section 250

sales turnover mismatch and (ii) increase in capital. He has submitted that the issue of deemed dividend was not listed for the purpose of scrutiny assessment. Therefore, the AO was not justified in making the impugned addition u/s.2(22)(e) of the Act by converting the limited assessment into full ... scrutiny assessment without the permission of the Anmol Himanshu Patel (Legal Heir of Late Himanshu Raojibhai Patel) vs. DCIT Asst.Year 2015-16. competent authority and making the addition on the issue of deemed dividend u/s.2(22)(e) of the Act. He, in this respect, has relied upon the decision

Gopal Snacks Pvt Ltd, Rajkot vs. Asst. Commissioner of Income Tax, Circle-1(1), Rajkot

ITA 499/RJT/2025[2020-21]Status: DisposedITAT Rajkot08 Dec 2025AY 2020-21

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita Nos. 498 & 499/Rjt/2025 "नधा"रणवष"/ Assessment Years: 2015-16 & 2020-21 बनाम Gopal Snacks Pvt. Ltd. Asst. Commissioner Of Plot No.2322-2324, Gidc Metoda, Income Tax Vs. Lodhika, Rajkot, Gujarat-360021 Circle-1(1), Rajkot Pan : Aadcg6113A (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राज"व क" ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई क" तार"ख /Date Of Hearing : 19/11/2025 घोषणा क" तार"ख /Date Of Pronouncement : 08/12/2025

For Appellant: Shri Prakash Jhunjhunwala and ShriFor Respondent: Shri Shramdeep Sinha, CIT.DR &
Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 154Section 154(3)Section 250Section 80J

assessing officer, vide order dated 19.09.2022, passed by the assessing officer under section 143(3) r.w.s.144B of the Act. In the said scrutiny assessment, under section 143 (3) of the Act, the assessing officer, by mistake, copy paste the income processed under section 143(1) by CPC(Central Processing Unit ... merged with the order passed by the assessing officer under section 143(3) of the Act dated 19.09.2022 and in the said scrutiny assessment proceedings, the assessing officer has allowed the deduction claimed by the assessee, under section 80JJAA of the Act to the tune of Rs.3

Gopal Snacks Pvt Ltd, Rajkot vs. Asst. Commissioner of Income Tax, Circle-1(1), Rajkot

ITA 498/RJT/2025[2015-16]Status: DisposedITAT Rajkot08 Dec 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita Nos. 498 & 499/Rjt/2025 निर्धारणवर्ष /Assessment Years: 2015-16 & 2020-21 Gopal Snacks Pvt. Ltd. बनाम Asst. Commissioner Of Income Tax Circle-1(1), Rajkot Plot No.2322-2324, Gidc Metoda, Lodhika, Rajkot, Gujarat-360021 (अपीलार्थी/Appellant) Pan : Aadcg6113A (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राजस्व की ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई की तारीख/Date Of Hearing : 19/11/2025 घोषणा की तारीख/Date Of Pronouncement : 08/12/2025 Order Per, Dr. Arjun Lal Saini: Captioned Two Appeals Filed By The Same Assessee, Pertaining To

For Appellant: Shri Prakash Jhunjhunwala and ShriFor Respondent: Shri Shramdeep Sinha, CIT.DR &
Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 154Section 154(3)Section 250Section 80J

assessing officer, vide order dated 19.09.2022, passed by the assessing officer under section 143(3) r.w.s.144B of the Act. In the said scrutiny assessment, under section 143 (3) of the Act, the assessing officer, by mistake, copy paste the income processed under section 143(1) by CPC(Central Processing Unit ... merged with the order passed by the assessing officer under section 143(3) of the Act dated 19.09.2022 and in the said scrutiny assessment proceedings, the assessing officer has allowed the deduction claimed by the assessee, under section 80JJAA of the Act to the tune of Rs.3