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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

Birlasoft Limited, Pune vs. DCIT, Circle 8, Pune

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

ITA 1116/PUN/2023[2018-19]Status: DisposedITAT Pune24 Nov 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Birlasoft Limited Dcit, Circle – 8, Pune 35 & 36, Rajiv Gandhi Infotech Vs. Park, Phase-1, Midc, Hinjawadi, Pune – 411057 Pan: Aaack7308N (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 30-09-2025 Date Of Pronouncement : 24-11-2025 O R D E R Per R.K. Panda, V.P: This Appeal Filed By The Assessee Is Directed Against The Order Dated 23.08.2023 Of The Ld. Cit(A) / Nfac, Delhi Relating To Assessment Year 2018-19. 2. Facts Of The Case, In Brief, Are That The Assesse Is A Public Limited Company & Is Engaged In The Business Of Computer & Software Services. It Filed Its Return Of Income On 29.11.2018 Declaring Total Income Of Rs.95,13,15,400/-. The Return Was Processed By The Cpc & An Intimation U/S 143(1) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Was Passed On 25.01.2021 Determining The Total Income At Rs.1,00,23,03,750/-. The Case Was Selected For Complete Scrutiny Assessment Under The E-Assessment Scheme, 2019 On The Following Issues:

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10ASection 10A(3)Section 143(1)Section 143(2)Section 27Section 36(1)(va)Section 51Section 80ISection 90

passed on 25.01.2021 determining the total income at Rs.1,00,23,03,750/-. The case was selected for complete scrutiny assessment under the E-assessment Scheme, 2019 on the following issues: 2 S. No. Issues i. Claim of Any Other Amount Allowable as Deduction in Schedule BP ii. Double Taxation

Chandra Panneerselvam, Vellore vs. PCIT., Chennai

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

ITA 91/CHNY/2025[2015-16]Status: DisposedITAT Chennai21 Nov 2025AY 2015-16

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.91/Chny/2025 Assessment Years: 2015-16 Chandra Pannerselvam, Principal Commissioner Of Income No.2/2, Old Munsif Court Street, Tax, Saidapet, Vellure, Circle-1, Tamil Nadu - 632 012. Vellore. [Pan: Aahpp9253B] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Mr.N.Arjun Raj, Advocate प्रत्यर्थी की ओर से /Revenue By : Mr.Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 16.10.2025 घोषणा की तारीख /Date Of Pronouncement : 21.11.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Mr.N.Arjun Raj, AdvocateFor Respondent: Mr.Bipin C.N, CIT
Section 143(3)Section 263

unregistered documents as mentioned in the notice. 6.2. The sources for investment in two immovable properties were explained and submitted at the time of scrutiny assessment and were thoroughly examined by the Assessing Officer and accepted. 6.3. All the expenses along with vouchers, supporting documents and books of account were ... examined by the Assessing Officer at the time of scrutiny assessment and disallowed a part of expenses claimed for want of supporting materials for few items of expenses and nothing has been omitted by the Assessing Officer to examine thoroughly. This fact is clearly mentioned in the assessment order passed

Nirmala Thomas, Gudalur vs. ITO, Ward-1, Ooty

In the result, the appeal of the assessee is allowed

ITA 672/CHNY/2025[2022-23]Status: DisposedITAT Chennai21 Nov 2025AY 2022-23

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.672/Chny/2025 Assessment Years: 2022-23 Nirmala Thomas Income Tax Officer, No.12/342-A G.V.Estate, Ward-1, Thorapalli, Gudalur, Ooty. Tamil Nadu-643 212 [Pan: Aetpt3435K] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Shri S.Girish Kumar, Advocate प्रत्यर्थी की ओर से /Revenue By : Ms.Gouthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 19.09.2025 घोषणा की तारीख /Date Of Pronouncement : 21.11.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Shri S.Girish Kumar, AdvocateFor Respondent: Ms.Gouthami Manivasagam, JCIT
Section 56

deposit in the bank account notice was given and the appellant filed submissions claiming the amount as her husband's agricultural receipts. During the scrutiny assessment, she has to file sufficient evidence to substantiate her claim. In the absence of basic proof it is not possible to accept the cash ... joint bank account holder. 5.0 We have heard rival submissions on the matter in the light of material available on records. The scrutiny assessment was undertaken to examine the veracity of agricultural income of the assessee. There were indications that the income declared during the year was at variance with