← All Phrases

“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

Sagarlaxmi Agriseeds Private Limited, Ahmedabad vs. The ACIT, Circle-4(1)(1), Ahmedabad

In the result, appeal of the assessee stands allowed

ITA 1918/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad05 Aug 2025AY 2017-18

Bench: S/Shri Sanjay Garg & Narendra Prasad Sinhaassessment Year : 2017-18 Sagarlaxmi Agriseeds Pvt Ltd Acit, Cir.4(1)(1) 206, Ashwamegh Avenue Vs Ahmedabad. Opp: Mithakhali Garden Navrangpura Ahmedabad. Pan : Aawcs 7561 F (Respondent) (Appellant) Assessee By : Shri Deepak R. Shah, Ar Revenue By : Shri Dharnidas V.S., Sr.Dr सुनवाई की तारीख/Date Of Hearing : 15/05/2025 घोषणा की तारीख /Date Of Pronouncement: 05/08/2025 आदेश/O R D E R

For Appellant: Shri Deepak R. Shah, ARFor Respondent: Shri Dharnidas V.S., Sr.DR
Section 143(1)Section 143(2)Section 143(3)Section 250Section 32

direct nexus between the available material and formation of such view. 4.It is further clarified that in cases under 'Limited Scrutiny', the scrutiny assessment proceedings would initially be confined only to issues under 'Limited Scrutiny and questionnaires, enquiry, investigation etc. would be restricted to such issues. Only upon conversion ... discussion in the preceding paragraphs it is once again reiterated that the Assessing Officers should abide by the instructions of CBDT while completing limited scrutiny assessments and should be scrupulous about maintenance of note sheets in assessment folders. (Rakesh Gupta) ADG (V) HQ-I New Delhi” 10. Admittedly, in this

Reena Bhatia, Ludhiana, Punjab vs. Jao the Income Tax Officer Ward 7(1) Ldh, Punjab

In the result, the sale figures for April to June, 2017 for Rs

ITA 339/CHANDI/2025[2018-2019]Status: DisposedITAT Chandigarh04 Aug 2025AY 2018-2019

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.339/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2018-19) Ms. Reena Bhatia Ito Ward-7(1) 64-C, Civil Lines Ludhiana. 141001 बनाम/ Vs. Udham Singh Nagar Ludhiana-141001 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Abfpb-7700-G (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 17-07-2025 घोषणाकीतारीख /Date Of Pronouncement : 04-08-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2018-19 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 10-01-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) Of The Act On 03-06-2021. Having Heard Rival Submissions & Upon Perusal Of Case Records, The Appeal Is Disposed-Off As Under.

For Appellant: Sh. Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR
Section 143(3)Section 44ASection 69A

details to lower authorities. Similar business income is reflected by the assessee in AY 2017-18 which have been accepted by Ld. AO in scrutiny assessment u/s 143(3) vide order dated 20-12-2019. The conclusion that the business is not genuine is on mere presumptions only without there