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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

Jks Abasan LLP, Kolkata vs. ACIT, Circle 1(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 594/KOL/2025[2017-2018]Status: DisposedITAT Kolkata24 Feb 2026AY 2017-2018

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2017-18 Jks Abasan Llp…………….....……..………………….……….……….……Appellant P-4, Black Lanen, Kol-700012. [Pan: Aalfj9634N] Vs. Acit, Circle-1(1), Kolkata..…...……...…………………….....……...…..…..Respondent Appearances By: Shri Miraj D Shah, Ar, Appeared On Behalf Of The Appellant. Shri S. Datta, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 29, 2026 Date Of Pronouncing The Order : February 24, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 10.03.2025 Of The Nfac, Delhi Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2017–18. 2. At The Very Outset, The Assessee Has Challenged By Taking Legal Ground That Notice U/S 143(2) Of The Act Dated 21.08.2018 Is Not In Conformity With The Instruction Issued By Cbdt Instruction No.1/2011 Dated 31.01.2011 & Since The Notice Issued U/S 143(2) Is Defective, The Assessment Order Is Void & Fit To Be Quashed. The Ld. Counsel Further Submits That Since Legal Issue Goes To The Root Of The Matter, Therefore, The Same May Be Admitted For Adjudication. After Considering The Facts Of Jks Abasan Llp The Case & Keeping In View The Decisions Of The Hon’Ble Apex Court In The Case Of National Thermal Power Co. Ltd V. Cit [1998] 229 Itr 383, We Are Inclined To Admit The Legal Ground For Adjudication.

Section 143Section 143(2)Section 143(3)Section 250

falls for consideration in the instant case is whether there is valid notice issued under Section 143 (2) of the Act for commencing the Scrutiny assessment. The Tribunal has noted the facts and rendered a finding that on the date when the case was selected for scrutiny, the authority

Kiran Bala Gupta, Hyderabad vs. ITO, Ward-10(1), Hyderabad

In the result, appeal filed by the assessee is partly allowed in terms of our aforesaid observations

ITA 341/HYD/2025[2012-13]Status: DisposedITAT Hyderabad20 Feb 2026AY 2012-13

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.341/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2012-13) Smt. Kiran Bala Gupta, Vs. Income Tax Officer, Hyderabad. Ward-10(1), Pan: Ahvpg6893K Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Av Raghuram, Advocate राज" व "ारा/Revenue By: Ms. Aditi Goyal, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 04/02/2026 घोषणा की तारीख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 20/12/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 271(1)(C) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 30/08/2022 For The Assessment Year (Ay) 2012-13. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri AV Raghuram, AdvocateFor Respondent: Ms. Aditi Goyal, Sr. AR
Section 10(38)Section 143(2)Section 143(3)Section 271(1)(c)

filed her return of income on 23/11/2012 declaring an income of Rs.44,83,200/-. Subsequently, the case of the assessee was selected for scrutiny assessment under section 143(2) of the Act. Thereafter, the AO framed the assessment vide order passed under section 143(3) of the Act, dated 26/03/2015

Ameenamma Charitble Trust, Anantapur vs. ITO, (Exemption) Ward-Tirupati, Tirupati

In the result, appeal filed by the assessee Trust is partly allowed in terms of our aforesaid observations

ITA 1841/HYD/2025[2016-17]Status: DisposedITAT Hyderabad20 Feb 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1841/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Ameenamma Charitable Vs. Income Tax Officer Trust, (Exemption) Ward – Anantapur. Tirupati. Pan: Aaeta7403P (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ka Sai Prasad, Ca राज" व "ारा/Revenue By: Shri K Vamsi Krishna, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 04/02/2026 घोषणा की तारीख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Trust Is Directed Against The Order Passed By The Additional/Joint Commissioner Of Income Tax (Appeals)-1, Chennai, Dated 03/10/2025, Which In Turn Arises From The Order Passed By The Income Tax Officer, Exemption Ward, Tirupati (For Short, “Ao”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 14/12/2018 For The Assessment Year (Ay) 2016-17. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri KA Sai Prasad, CAFor Respondent: Shri K Vamsi Krishna, Sr.AR
Section 11Section 11(1)Section 11(2)Section 115BSection 12ASection 13(9)Section 139(1)Section 143(2)Section 143(3)Section 250

income of Rs. NIL, after claiming exemption under section 11 of the Act. Subsequently, the case of the assessee company was selected for scrutiny assessment under section 143(2) of the Act. 3. During the course of the assessment proceedings, the AO observed that the assessee Trust during the subject

Tharmiya Subramanian Ramila, Madurai vs. ITO, Ward-1(7), Madurai

ITA 3503/CHNY/2025[2014-15]Status: DisposedITAT Chennai19 Feb 2026AY 2014-15

Bench: Shri S.S. Viswanethra Ravi & Ms. S. Padmavathyआयकर अपील सं./I.T.A. No.3503/Chny/2025 िनधा"रण वष"/Assessment Year: 2014-15 Thamiya Subramanian Ramila, Vs. The Income Tax Officer, No. 391, K.K. Nagar, 8Th East Street, Ward 1(7), Madurai 625 020. Madurai. [Pan:Aehpr1869M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri P. Ranga Ramanujam, Ca ""थ" की ओर से/Respondent By : Ms. Latchana, Jcit सुनवाई की तारीख/ Date Of Hearing : 16.12.2025 घोषणा की तारीख /Date Of Pronouncement : 19.02.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 04.02.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2014-15. 2. We Find That This Appeal Is Filed With A Delay Of 226 Days. The Assessee Filed An Affidavit For Condonation Of Delay Explaining The Reasons That She Is An Illiterate & Her Husband Has To Look After The Tax Matters

For Appellant: Shri P. Ranga Ramanujam, CAFor Respondent: Ms. Latchana, JCIT
Section 143(3)Section 148Section 2(14)Section 54BSection 54F

that the assessee is an individual and filed return of income declaring a total income ₹.2,87,700/- and the Assessing Officer completed the scrutiny assessment under section 143(3) of the Act by making addition of ₹.3,00,900/- on account of claim of deduction under section