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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

Sun Ark Aluminium Industries Pvt. Ltd., Virudhunagar vs. ITO, Corporate Circle, Madurai

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

ITA 2071/CHNY/2025[2018-19]Status: DisposedITAT Chennai24 Oct 2025AY 2018-19

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:2071/Chny/2025 यनिाारणवर्ा / Assessment Year:2018-19 Sun Ark Aluminium Income Tax Officer, Industries Private Limited, Vs. Corporate Circle, No.22, Chairman A, Madurai. Shanmugam Road, Sivakasi, Virudhunagar, Tamil Nadu-626 123. [Pan:Aalcs3262Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr.G.Baskar, Advocate, प्रत्यर्थीकीओरसे/Revenue By : Mr.C.P.Solomon, Jcit.

For Appellant: Mr.G.Baskar, AdvocateFor Respondent: Mr.C.P.Solomon, JCIT
Section 142(1)Section 143(2)Section 143(3)Section 263

enclosing complete details of import purchases together with the import documents thereon. It was also submitted before the Ld. PCIT that since the original scrutiny assessment was selected for limited scrutiny under the e- Page 3 of 6 ITA. No:2071/Chny/2025 assessment scheme of 2019 which mandated and warranted ... dispute that the assessee had indeed furnished the details of import purchases together with import documents thereon before the Ld.AO in the scrutiny assessment proceedings itself. But the Ld. PCIT is only trying to expand the scope of limited scrutiny by stating that the Ld.AO ought to have examined

Anjali Jain, Delhi vs. ITO Ward 53(1), Delhi

In the result, appeal of the assessee is partly allowed

ITA 3239/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Oct 2025AY 2017-18

Bench: Shri Vikas Awasthyआअसं.3239/िद"ी/2025 (िन.व. 2017-18) Anjali Jain, ...... अपीलाथ"/Appellant R-25, Ndse-Ii, New Delhi 110049 Pan: Aaipj-2323-D बनाम Vs. Income Tax Officer, Ward-53(1) ..... "ितवादी/Respondent Civic Centre, New Delhi 110002 अपीलाथ" "ारा/Appellant By : S/Shri Sanchit Jain, Chartered Accountant & Archit Agarwal, "ितवादी"ारा/Respondent By : Ms. Sudha Gupta, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 29/07/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 24/10/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short ‘The Cit(A)’] Dated 11.04.2025, For Assessment Year 2017-18.] 2. Shri Sanchit Jain, Appearing On Behalf Of The Assessee Submitted That The Assessee Is Engaged In The Business Of Manufacturing & Trading Of Gold, Diamond & Precious Stone Jewelry. For The Impugned Assessment Year, The Assessee Filed Her Return Of Income On 31.10.2017 Declaring Total Income Of Rs.4,99,260/-. The Case Of The Assessee For Ay 2017-18 Was Reopened & Notice U/S. 148 Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’) Dated

For Appellant: S/Shri Sanchit Jain, Chartered Accountant &For Respondent: Ms. Sudha Gupta, Sr. DR
Section 148Section 151Section 69A

reopened asthere were cash deposits of Rs.11,34,500/- in the bank account of the assessee. During the course of scrutiny assessment proceedings the assessee explained the source of cash deposits as under:- Amount Source Rs.2,40,000/- Past savings of the assessee (Stree Dhan) Rs.4,00,000/- Earlier withdrawals

Sri Prem Properties Private Limited, Gurgaon vs. ACIT, Circle-24(1), New Delhi, Delhi

In the result, appeal filed by the assessee is allowed

ITA 957/DEL/2024[2012-13]Status: DisposedITAT Delhi24 Oct 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Sri Prem Properties Private Limited, Vs. Acit, Circle 24 (1), A – 99, Bajghera Chowk, Delhi. New Palam Vihar, Gurgaon – 122 017 (Haryana). (Pan :Aaacs2554E) (Appellant) (Respondent) Assessee By : Dr. Rakesh Gupta, Advocate Shri Skasham Agarwal, Ca Shri Deepesh Garg, Advocate Revenue By : Ms. Kirti Sankratyayan, Cit Dr Date Of Hearing : 01.09.2025 Date Of Order : 24.10.2025 Order Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income-Tax (Appeals)-23, New Delhi [For Short ‘Ld. Cit (A)]Dated 04.01.2024 For Assessment Year 2012-13. 2. Brief Facts Of The Case Are, Assessee Filed Its Original Return Of Income On 30.09.2012 Declaring An Income Of Rs.2,15,340/-. The Case Of The Assessee Was Selected For Scrutiny For The Year Under Consideration.

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Ms. Kirti Sankratyayan, CIT DR
Section 132Section 147Section 148

observed that BIDPL has adopted the same modus operandi to claim forfeited amount as business expenses in AYs 2013-14 and 2014-15 respectively. Scrutiny assessment of BIDPL was completed and made addition of Rs.5 crores as forfeiture amount of earnest money. They also observed that the group is involved

Juniper Networks Solution India Private Limited, New Delhi vs. Assessment Unit, NFAC Itd, New Delhi

In the result, ground no 3 raised by the assessee is allowed in its favour

ITA 4400/DEL/2024[2020-21]Status: DisposedITAT Delhi24 Oct 2025AY 2020-21

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Juniper Networks Solution India Pvt. Ltd., Vs. Assessment Unit, Unit No.Iia, 06Th Floor, Dlf Centre, Nfac Itd, Parliament Street, Connaught Place, New Delhi – 110 001. (Pan : Aaecj1345A) (Appellant) (Respondent) Assessee By : Shri Sachit Jolly, Sr. Advocate Shri Sandeep Bhalla, Advocate Shri Anurag Singhal, Ca Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 05.08.2025 Date Of Order : 24.10.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 27.07.2024 Passed By The Income Tax Department, Assessment Unit U/S 143(3) Read With Section 144C(13)/144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020-21 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

For Appellant: Shri Sachit Jolly, Sr. AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR
Section 115JSection 142(1)Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 92C

declaring total loss of Rs.49,78,97,850/-and deemed total income u/s 115JB at Rs.0/-. The case of the assessee was selected for scrutiny assessment under CASS, therefore notice u/s 143(2) of the Income-tax Act, 1961 was issued to the assessee company vide notice bearing DIN: ITBAIAST/S/143