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“limited scrutiny”

Assessment ProceduresSection 143(3)Section 143(3)2,866 judgments

The decision most relied on for limited scrutiny is Vipan Khanna v. CIT (255 ITR 220), cited in 140 judgments on BharatTax.

Leading authorities on limited scrutiny

Vipan Khanna v. CIT
255 ITR 220 · 2002 · High Court
140
citing judgments

Assessment proceedings conclude and become final if a scrutiny notice under Section 143(2) is not served within the prescribed statutory period. This case also clarified the historical position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.

Duggal & Co. v. CIT
220 ITR 456 · 1996 · High Court
84
citing judgments

An assessment order becomes erroneous and prejudicial to the revenue under Section 263 if the Assessing Officer fails to conduct a proper inquiry or investigation, even if the return appears prima facie correct. The Income-tax Officer has a duty to investigate and cannot remain passive.

Amal Kumar Ghosh v. Asstt. CIT
361 ITR 458 · 2014 · High Court
39
citing judgments

The selection of cases for scrutiny must be completed within the time prescribed by CBDT instructions. The department is bound by its own standards and cannot act with discrimination or selectively apply them.

PCIT v. Weilburger Coatings (India) (P.) Ltd.
155 Taxmann.com 580 · 2023 · High Court
31
citing judgments

Assessing officers cannot introduce issues for inquiry that were not part of the original limited scrutiny, without adhering to mandatory procedural requirements.

Balvinder Kumar v. PCIT
125 Taxmann.com 83 · 2021 · High Court
25
citing judgments

An Assessing Officer cannot travel beyond the scope of issues selected for limited scrutiny during the assessment proceedings.

PCIT v. Shark Mines and Minerals (P.) Ltd.
151 Taxmann.com 71 · 2023 · High Court
25
citing judgments

Revisionary powers under Section 263 cannot be invoked to find fault with an assessment order on an issue not covered by 'limited scrutiny' where the Assessing Officer could not have examined such an issue.

CIT v. Smt. Padmavathi
120 Taxmann.com 187 · 2020 · High Court
20
citing judgments

An assessment order cannot be held erroneous and prejudicial to revenue if the Assessing Officer (AO) could not have travelled beyond the issues forming the subject matter of 'limited scrutiny'. The Principal Commissioner of Income Tax (PCIT) cannot invoke Section 263 to set aside an assessment on grounds not forming part of the limited scrutiny.

Mahanagar Telephone Nigam Ltd. v. Chairman, Central Board of Direct Taxes and Another
246 ITR 173 · 2000 · High Court
13
citing judgments

An Assessing Officer can initiate reassessment proceedings under Section 147 even if a scrutiny notice under Section 143(2) was not issued within the prescribed time, provided the conditions for Section 147 are met. An intimation under Section 143(1)(a) does not preclude recourse to Section 147.

Judgments citing limited scrutiny

Ashok Kumar, Haryana vs. Pr, CIT, Rohtak, Haryana

In the result, the appeal of the assessee is allowed

ITA 580/DEL/2021[2016-17]Status: DisposedITAT Delhi21 Mar 2024AY 2016-17

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaassessment Year: 2016-17 Ashok Kumar, Vs Pcit, S/O Naseeb Chand, Rohtak, Dangra Road, Near Bus Stand, Haryana. Tohana, Distt. Fatehabad, Haryana – 125120. Pan: Ammpk4875B (Applicant) (Respondent) Assessee By : Shri Lalit Mohan, Ca Revenue By : Ms Sunita Verma, Cit, Dr Date Of Hearing : 04.03.2024 Date Of Pronouncement : 21.03.2024

For Appellant: Shri Lalit Mohan, CAFor Respondent: Ms Sunita Verma, CIT, DR
Section 143(3)Section 263Section 263(1)

Fatehabad (hereinafter referred as the Ld. AO). Ashok Kumar vs. PCIT 2. The assessee had filed return of income which was picked up for limited scrutiny to examine the issue: ‘Whether the investment and income relating to the securities are duly disclosed.’ The assessment was completed ... order of ld. PCIT not bearing DIN was not pressed. 9. It comes up that the notice u/s 143(2) of the Act for limited scrutiny was issued on 29.09.2017 where the primary query under consideration was ‘whether the investment and income relating to security transactions are duly disclosed’ (copy

Chander Mohan, Delhi vs. Income Tax Officer Ward 49(1), Delhi

Appeal of the assessee is allowed for statistical purposes

ITA 119/DEL/2024[2016-17]Status: HeardITAT Delhi19 Mar 2024AY 2016-17

Bench: Shri Kul Bharatassessment Year: 2016-17

Section 144

facts & law for making addition of Rs 25,80,160/- other than the issues for which assessee's case has been selected for, limited scrutiny ie whether the cash deposit has been made from disclosed sources overlooking the board instruction in respect of Limited scrutiny. Therefore assessment order passed ... that for A.Y. 2016-17 the assessee filed his return of income declaring income of Rs. 17,54,620/-. The case was selected for limited scrutiny under CASS. It is seen from the assessment order that the assessee did not comply with the statutory notices issued by the AO. Accordingly

Chinta Sravan Kumar, Anantapur vs. Income Tax Officer, Ward-1, Anantapur

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

ITA 161/HYD/2024[2017-18]Status: DisposedITAT Hyderabad18 Mar 2024AY 2017-18

Bench: Shri K. Narasimha Chary

For Appellant: Mr. Chinta Sravan KumarFor Respondent: Shri P.V. Subba Raju, DR

were in the month of March, 2017. 5. Learned CIT(A) examined the record and found that the case was selected for limited scrutiny with a reason “to verity cash deposits during demonetization period”. Learned CIT(A) further found that out of the total deposits

Income Tax Officer, Ward-1(1), Tirupati vs. Devapatla Subhadramma, Tirupati

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

ITA 581/HYD/2023[2016-17]Status: DisposedITAT Hyderabad18 Mar 2024AY 2016-17

Bench: Shri R.K. Panda, Vice- & Shri K. Narasimha Charyआ.अपी.सं /Ita No.581/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2016-17) Income Tax Officer Vs. Smt. Devapatla Ward – 1 (1) Subhadramma Tirupati Tirupati Pan:Ayqps6231H (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A.Sai Prasad, Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr सुनवाई की तारीख/Date Of Hearing: 05/03/2024 घोषणा की तारीख/Pronouncement: 18/03/2024 आदेश/Order

For Appellant: Shri K.A.Sai Prasad, CAFor Respondent: : Shri Shakeer Ahmed, DR
Section 143(2)Section 144

filed her return of income for the impugned A.Y on 23.3.2018 declaring total income of Rs.4,72,520/-. The case was selected for limited scrutiny to verify the (i) cash deposits and transaction in property and (ii) capital gain/loss on sale of property. The Page

Konathala Nooku Naidu, Anakapalle vs. The Income Tax Officer, Ward-1, Anakapalle

In the result, appeal of the assessee is partly allowed

ITA 269/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam18 Mar 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.269/Viz/2023 (निर्धारण वर्ा / Assessment Year : 2017-18) Konathala Nooku Naidu, Vs. The Income Tax Officer, Anakapalle. Ward-1, Pan: Aczpn 4551 C Anakapalle. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थी की ओर से/ Appellant By : Sri Gvn Hari, Ar प्रत्यधर्थी की ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar सुिवधई की तधरीख / Date Of Hearing : 12/03/2024 घोर्णध की तधरीख/Date Of : 18/03/2024 Pronouncement O R D E R Per Duvvuru Rl Reddy:

For Appellant: Sri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 142(1)Section 143(2)Section 143(3)Section 69A

declaring a total income of Rs. 5,28,089/- under ‘Short Term Capital Gains’ [STCG] and ‘other sources’. Subsequently, the case was selected for Limited Scrutiny under CASS to examine the cash deposits made by the assessee during the demonetization period and the claim of exemption of agricultural income. Subsequently

Viswaat Chemicals Limited, Mumbai vs. CIT(A)-54, Earnest House

In the result, original grounds no

ITA 3494/MUM/2023[2018-19]Status: DisposedITAT Mumbai15 Mar 2024AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri Gagan Goyalviswaat Chemicals Limited, 909/910 Eco Star, Vishweshwar Nagar, Behind Udupi Vihae Hotel, Mumbai-400 063 Pan: Aaacv4184B ...... Appellant Vs. Dcit Cen. Cir. 6(3), 102, 1St Floor, Earnest House, Ncpa Marg, Nariman Point Mumbai- 400021 ..... Respondent

For Appellant: Shri Ronak Doshi, Ld. ARFor Respondent: Ms. Rajeshwari Menon, Ld. DR
Section 234BSection 250Section 28Section 35Section 35(1)Section 35(1)(i)Section 37

income on 09-10-2018, declaring a total income of Rs. 6,45,38,970/-. The Case of the assessee was selected for limited scrutiny on the issue of Duty Drawbacks and Deduction on account of donation for scientific research. During the assessment proceedings, AO disallowed a deduction

Sridhar Yarlagadda, Visakhapatnam vs. Income Tax Officer, Ward-3(2), Visakhapatnam

In the result, appeal filed by the assessee is dismissed

ITA 311/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam14 Mar 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.311/Viz/2023 (निर्धारण वर्ा / Assessment Year : 2017-18) Sridhar Yarlagadda, Vs. Income Tax Officer, Visakhapatnam. Ward-3(2), Pan: Abdpy4072 G Visakhapatnam. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थी की ओर से/ Appellant By : None प्रत्यधर्थी की ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar

For Appellant: NoneFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 115BSection 133(6)Section 142(1)Section 143(2)Section 144Section 44ASection 68Section 69A

Subsequently, the return of income was revised on 30/08/2017 admitting an income of Rs.5,24,450/-. Thereafter, the case was selected for limited scrutiny under CASS to verify the cash deposits during the demonetization period. Subsequently, notice U/s. 143(2) was issued on 09/08/2018 and served on the assessee

The Incoda, Kolkata vs. ACIT, Cir. 30, Kolkata

In the result, the appeal filed by the assessee is allowed

ITA 1304/KOL/2023[2015-16]Status: DisposedITAT Kolkata13 Mar 2024AY 2015-16

Bench: Dr. Manish Borad & Sri Anikesh Banerjee

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

advertisement etc. Income of Rs. 59,08,011/- declared in the return of income for AY 2015-16 furnished on 05.10.2015. Case selected for limited scrutiny through CASS followed by serving of notices u/s 143(2) & 142(1) of the Act. The reason for selecting the case for limited scrutiny

Ayur Green Ayurveda Hospitals Private Limited, Malappuram vs. DCIT, CPC, Bengaluru

In the result, the assessee’s appeal is dismissed

ITA 565/COCH/2022[2018-2019]Status: DisposedITAT Cochin13 Mar 2024AY 2018-2019

Bench: Shri Sanjay Arora & Dr. S. Seethalakshmiayurgreen Ayurveda Hospsitals Vs Dcit, Private Limited Cpc, Door No. 1/301 Ayurgreen Bengaluru. Ayurveda Hospitals, Kaladi Mlp Edappal, Malappuram-679585. (Appellant) (Respondent) Pan No. Aaica 4294 M

For Appellant: NoneFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 143(1)Section 2Section 30Section 36Section 36(1)(va)Section 43B

CASS and the Assessing Officer cannot go beyond the reasons for scrutiny selection and such 19 Ayurgreen Ayurveda Hospitals Pvt. Ltd. cases are called Limited Scrutiny cases and only the remaining returns are taken up for complete scrutiny u/s 143(3) of the Act. 13.2 Meaning thereby, that exercise

M/S. Wealth Vruddhi Financial Services, Bangalore vs. Income Tax Officer, Ward-1(2)(1), Bangalore

In the result, the appeal filed by the Assessee stands allowed for statistical purposes

ITA 62/BANG/2024[2018-19]Status: DisposedITAT Bangalore13 Mar 2024AY 2018-19

Bench: Shri N. K. Choudhry, Jm & Shri Laxmi Prasad Sahu, Am

For Appellant: Shri S.V. Ravishankar, AdvocateFor Respondent: Shri Subramanian. S, JCIT
Section 143(3)Section 144BSection 250Section 270Section 270A(1)Section 270A(8)Section 270A(9)(c)Section 274

instant case, the Assessee had declared its income at Rs.’Nil’ by filing its return of income on 14.8.2018, which was selected for limited scrutiny under CASS on the issue “Large Sales promotion expenses vis-à-vis gross receipts”, which resulted into passing an Assessment Order dated

Umesh Ambikaprasad Mishra, Mumbai vs. ITO 10(3)(3), Mumbai

In the result, appeal filed by the assessee is partly allowed as per

ITA 4620/MUM/2019[2012-13]Status: DisposedITAT Mumbai13 Mar 2024AY 2012-13

Bench: Shri Narendra Kumar Choudhry, Hon’Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 142(1)Section 143(3)Section 68

facts and circumstances of the case.” 9. At the time of hearing, Ld.AR of the assessee submitted that the ground challenging the “converting the limited scrutiny into complete scrutiny” is not pressed, accordingly, the same is dismissed as not pressed. 10. With regard to ground relating to Addition under section

Umesh A Mishra, Mumbai vs. ITO 10(3)(3), Mumbai

In the result, appeal filed by the assessee is partly allowed as per

ITA 1848/MUM/2018[2011-12]Status: DisposedITAT Mumbai13 Mar 2024AY 2011-12

Bench: Shri Narendra Kumar Choudhry, Hon’Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 142(1)Section 143(3)Section 68

facts and circumstances of the case.” 9. At the time of hearing, Ld.AR of the assessee submitted that the ground challenging the “converting the limited scrutiny into complete scrutiny” is not pressed, accordingly, the same is dismissed as not pressed. 10. With regard to ground relating to Addition under section

Ajayshree Gramin Bigar Sheti Sahakari Patsanstha Maryadit, Pune vs. NFAC, Delhi

In the result, appeal of the assessee is allowed

ITA 1427/PUN/2023[2018-19]Status: DisposedITAT Pune08 Mar 2024AY 2018-19

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1427/Pun/2023 िनधा"रण वष" / Assessment Year : 2018-19 Ajayshree Gramin Bigar Sheti The National Faceless Sahakari Patasanstha Maryadit, V Assessment At Post Murum, Tal Baramati, S Centre(Nfac), Delhi. Dist Pune, Pune – 412306. Pan: Aaaaa9964E Appellant/ Assessee Respondent /Revenue Assessee By Shri Manoj R Jain – Ar Revenue By Shri Ramnath P Murkunde - Dr Date Of Hearing 06/03/2024 Date Of Pronouncement 08/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Dated 30.10.2023 For A.Y.2018-19. The Grounds Of Appeal Raised By The Assessee Are As Under : “1. The Learned Cit (A) Has Erred In Confirming The Addition Of Rs.86,59,612/-Made By The Ao On Account Of Disallowance Of Deduction Claimed By The Appellant U/S 80P(2)(A)(I) Of The Act Without Considering The Detailed Submissions Made By The Appellant & Without Passing Any Speaking Order, On The Ground That Only The Income Earned By Providing Credit Facility To Its Members Be Treated Ajayshree Gramin Bigar Sheti Sahakari Patasanstha Maryadit [A]

Section 143(3)Section 57Section 80PSection 80P(2)(a)

after claiming deduction under section 80P. 3 Ajayshree Gramin Bigar Sheti Sahakari Patasanstha Maryadit [A] 2.1 The assessee’s case was selected for limited scrutiny to verify deduction under Chapter-VIA of the Act. Accordingly, Assessing Officer(AO) issued various notices. Assessee filed its submission. AO observed in the assessment

Satyam Print House, Mumbai vs. Additional /Joint/ Deputy/Assistant Commissioner of Income Tax, Income Tax Officer, NFAC, Delhi

ITA 2898/MUM/2023[ 2018-19]Status: DisposedITAT Mumbai08 Mar 2024

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Pritesh MehtaFor Respondent: Shri Prashant Mahajan
Section 270ASection 50CSection 56(2)(x)

that the Assessee filed return of income for the Assessment Year 2018-19 on 23/09/2018. The case of the Assessee was selected for limited scrutiny in relation to issue of investment in immovable property. During the assessment proceedings, the Assessing Officer noted that the Assessee had purchased immovable property

Adarsh Global Trades and Services Private Limited, Hyderabad vs. ACIT., Central Circle - 2(3), Hyderabad

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

ITA 70/HYD/2024[2016-17]Status: DisposedITAT Hyderabad06 Mar 2024AY 2016-17

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2016-17 Adarsh Global Trades & Vs. The Assistant Commissioner Of Income Tax, Services Private Limited, Central Circle – 2(3), Hyderabad. Hyderabad. Pan : Aakca7278H. (Appellant) (Respondent) Assessee By: None Revenue By: Shri Sesha Srinivas, Cit-Dr 04.03.2024 Date Of Hearing: Date Of Pronouncement: 06.03.2024

For Appellant: NoneFor Respondent: Shri Sesha Srinivas, CIT-DR
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 271(1)(c)

u/s.139(1) of the Income tax Act on 16/10/2016 declaring total income of Rs.75,85,820/-. The case of the assessee was selected for limited scrutiny. Accordingly, Notices u/s 143(2) dated 27/07/2017 and 07/09/2017 were issued and served on the assessee. Thereafter, notice u/s 142(1) was issued

Hari Narayan Meena, Jaipur vs. Income-Tax Officer Ward 2(5), Jaipur

In the result, the appeal filed by the assessee is allowed for

ITA 56/JPR/2024[2016-17]Status: DisposedITAT Jaipur05 Mar 2024AY 2016-17

Bench: Commissioner Of Income-Tax (Appeals) Which Was Being Handled By The Earlier Authorized Representative & The Information & Details Of The Case Had Been Provided To The Assessee Recently Only.

For Appellant: Shri Ashish Sharma (Adv.)
Section 143(3)

income on 30.03.2017 declaring total income of Rs. 30,590/-, which was processed u/s 143(1). The case of the assessee was Selected for limited scrutiny under CASS. Notice u/s 143(2) was issued on 26.09.2017 and served upon the assessee. Thereafter, a notice u/s 142(1) has been issued ... placed reliance on the written submission which is extracted herein below:- “1. The Return filed at Income of Rs. 30,590/- was selected for limited scrutiny under CASS to examine and verify the sale of agricultural land for Rs.3,51,00,000/- and assessed

Vineet Agarwal, Kolkata vs. ITO, Ward 43(1), Kolkata

In the result, the appeal of the assessee being

ITA 1003/KOL/2023[2016-17]Status: DisposedITAT Kolkata04 Mar 2024AY 2016-17

Bench: Shri Sanjay Garg & Shri Rajesh Kumar

Section 133(6)Section 143(2)Section 143(3)Section 145(3)

year filed his return of income on 31.03.2017 disclosing a total income of Rs.2,54,790/-. The case of the assessee was selected for limited scrutiny for two reasons, namely- (i) Whether the value of exports and imports has been correctly shown in the return of income; (ii) Whether duty ... return of income on 31.03.2017 disclosing total income A.Ys. 2015-2016 & 2016-2017 Vineet Agarwal of Rs.5,70,840/-, which was selected for limited scrutiny for two reasons:- (i) whether value of exports and imports has been correctly shown in return of income; (ii) whether duty drawback received has been

Vineet Agarwal, Kolkata vs. ITO, Ward 43(1), Kolkata

In the result, the appeal of the assessee being

ITA 1002/KOL/2023[2015-16]Status: DisposedITAT Kolkata04 Mar 2024AY 2015-16

Bench: Shri Sanjay Garg & Shri Rajesh Kumar

Section 133(6)Section 143(2)Section 143(3)Section 145(3)

year filed his return of income on 31.03.2017 disclosing a total income of Rs.2,54,790/-. The case of the assessee was selected for limited scrutiny for two reasons, namely- (i) Whether the value of exports and imports has been correctly shown in the return of income; (ii) Whether duty ... return of income on 31.03.2017 disclosing total income A.Ys. 2015-2016 & 2016-2017 Vineet Agarwal of Rs.5,70,840/-, which was selected for limited scrutiny for two reasons:- (i) whether value of exports and imports has been correctly shown in return of income; (ii) whether duty drawback received has been

Shail P Shah - HUF, Ahmedabad vs. The Pr. CIT-1, Ahmedabad

In the result, appeal of the assessee is allowed

ITA 72/AHD/2021[2015-16]Status: DisposedITAT Ahmedabad01 Mar 2024AY 2015-16

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2015-16

Section 143(3)Section 263Section 44A

erred on facts and in law by Initiating revision proceedings u/s.263 without appreciating that a case of the appellant was selected under CASS for limited scrutiny i.e. to verify transactions undertaken in commodity and derivative (futures) segment 2. The ld. Pr. CIT erred on facts and in law set aside ... erred on facts and in law by initiating revision proceedings under section 263 of the Act against the issues beyond the scope of limited scrutiny which legally not permissible. 5. The Id. Pr. CIT erred on facts and in law by ignoring the factual details already available on record

Somenath Duttagupta, Kolkata vs. ACIT, Cir-2(1), Kolkata

In the result, the appeal of the assessee stands allowed

ITA 627/KOL/2023[2019-20]Status: DisposedITAT Kolkata01 Mar 2024AY 2019-20

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.627/Kol/2023 Assessment Year: 2019-20 Somnath Duttagupta……..………….…................…...……………....Appellant A 168, Lake Gardens, Shivam Building Flat A2, Kolkata – 700045. [Pan: Afqpd5412G] Vs. Acit, Circle-2(1), Kolkata…...…..........................................…..…..... Respondent Appearances By: Shri Balaji V, Ar, Appeared On Behalf Of The Appellant. Shri Raja Sengupta, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 22, 2024 Date Of Pronouncing The Order : March 01, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 28.04.2023 Of The Commissioner Of Income Tax (Appeals)- 22, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Is Aggrieved By The Action Of The Lower Authorities In Making/Confirming The Addition Of Salary Income Of Rs.47,26,133/- Received By The Assessee In India For The Services Rendered In Us. 3. The Brief Facts Of The Case Are That The Assessee, An Individual, Filed His Revised Return Of Income For The Assessment Year Under Consideration I.E. A.Y 2019-20 Declaring A Total Income Of Rs.191370/-.

Section 250Section 90(4)

declaring a total income of Rs.191370/-. I.T.A. No.627/Kol/2023 Assessment Year: 2019-20 Somnath Duttagupta The case of the assessee was selected for limited scrutiny for the following reasons: 1. Salary income shown in ITR is less than the salary income as per 26AS 2. Salary income shown under Part