“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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

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

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

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

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

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

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

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

Kalhar Co. Op. Hsg. Society Ltd. Part-2, Gandhinagar vs. The ITO, Ward-1, Mehsana

In the result, appeal failed by the assessee is allowed

ITA 802/AHD/2023[2020-21]Status: DisposedITAT Ahmedabad31 Jan 2024AY 2020-21

Bench: Ms. Suchitra Kambleassessment Year: 2020-21

Section 143(1)Section 143(2)Section 143(3)Section 250Section 57

return of income was processed under Section 143(1) of the Income Tax Act, 1961. The case was selected under the category of limited scrutiny, the reason being deductions from income from other sources and high creditors/liabilities. Accordinbghly, notice under Section 143(2) of the Act dated

Vijay Rajnikant Patel, Ahmedabad vs. The Pr. CIT-3, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 409/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad31 Jan 2024AY 2018-19

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

For Appellant: Shri Pratik Gattani, A.RFor Respondent: Shri Kamlesh Makwana, CIT DR

Section 143(3)Section 263Section 57

That the Principal Commissioner erred in invoking provisions of section 263 of the Act on the issues other than those covered under limited scrutiny notice issued while completing original assessment under section 143(3) of the Act. 4. That the appellant craves leave to add/alter/delete/modify/substitute ... filed its return of income on 20.0.2018 declaring total income at Rs. 1,11,44,840/-. Upon selection of the case under the limited scrutiny assessment under the e-assessment scheme, 2019 the issue of deduction of interest under Section 57 of the Act has been finalized under Section

Kodandaram Nadavati, Nellore vs. Dy. Commissioner of Income Tax, Circle -1, Nellore

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

ITA 637/HYD/2023[2016-17]Status: DisposedITAT Hyderabad31 Jan 2024AY 2016-17

Bench: Shri R.K. Panda, Vice- & Shri K. Narasimha Charyआ.अपी.सं /Ita No.637/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2016-17 ) Shri Kodandaram Nadavati Vs. Dy. C. I. T. Nellore Circle 1 Pan:Afupn9767N Nellore (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Mohd.Afzal, Advocate राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 31/01/2024 घोषणा की तारीख/Pronouncement: 31/01/2024 Order Per R.K. Panda, Vice-. This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.01.2023 Of The Learned Cit (A)-Nfac Delhi, Relating To A.Y.2016-17. 2. Although A Number Of Grounds Have Been Raised By The Assessee, However, These All Relate To The Order Of The Learned Cit(A)-Nfac In Confirming The Addition Of Rs.63,48,500/-To The Total Income Of The Assessee By Not Condoning The Delay Of 138 Days In Filing Of The Appeal.

For Appellant: Shri Mohd.Afzal, AdvocateFor Respondent: : Shri Shakeer Ahmed, Sr.AR

Section 142(1)Section 143(3)Section 147Section 148Section 69A

Page 1 of 5 ITA No 637 of 2023 Kodandaram Nadavati agricultural income of Rs.85,700/-. The case was selected for limited scrutiny to verify as to whether the cash deposits made are from disclosed sources or not. The assessment was completed u/s 143(3) on 5.12.2018 wherein the returned

Asst. Commissioner of Income Tax, (Exemptions)-1, Hyderabad vs. Indo Arab League, Hyderabad

In the result, appeal filed by the Revenue is dismissed

ITA 2219/HYD/2017[2014-15]Status: DisposedITAT Hyderabad31 Jan 2024AY 2014-15

Bench: Shri R.K. Panda

For Appellant: Word gt /For Respondent: Shri K.C. Devdas, CA

Section 11Section 11(5)Section 12ASection 143(2)

claiming exemption u/s 11 of the Act. Thereafter, the assessee filed a revised manual return of income on 30.06.2015. The case was selected for limited scrutiny under CASS to verify the large receipts and large value of sale consideration of property. Accordingly statutory notices ... Winding up and dissolution clause (s), properties of the society etc. 2.2 In view of the above, the Assessing Officer converted the case from limited scrutiny to complete scrutiny after obtaining necessary approval from the concerned CIT (E). 3. The Assessing Officer observed that the assessee society filed its original

Sobha Devi Dilipkumar, Vijayawada vs. Income Tax Officer, Ward-2(1), Vijayawada

In the result, appeal of the assessee is allowed

ITA 108/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam31 Jan 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No. 108/Viz/2023 ("नधा"रण वष" / Assessment Year :2017-18) Sobha Devi Dilipkumar, Vs. The Income Tax Officer, Vijayawada. Ward-2(1), Pan: Abypd 3389 E Vijayawada. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri Gvn Hari, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Sri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 115BSection 142(1)Section 143(1)Section 143(2)Section 143(3)Section 69A

total income of Rs. 7,84,640/-. The return was processed U/s. 143(1) of the Act. Later on, the case was selected for ‘limited scrutiny’ under CASS for the reason to verify ‘cash deposits during the demonetization period’. Thereafter, notice U/s. 143(2) of the Act was issued

D.C.I.T., CC-1(3), Kolkata vs. M/S. Navin Construction & Credit Pvt. Ltd., Kolkata

In the result, appeal of the revenue is dismissed and cross- objection of the assessee is allowed

ITA 580/KOL/2022[2015-2016]Status: DisposedITAT Kolkata31 Jan 2024AY 2015-2016

Bench: Shri Sanjay Garg, Hon’Ble & Dr. Manish Borad, Hon’Ble

For Appellant: Shri Akkal Dudhewala, A/RFor Respondent: Shri Abhijit Kundu, CIT, D/R

Section 133(6)Section 14ASection 250Section 35Section 35(1)Section 68

legally untenable as the AO had acted in excess of jurisdiction by examining these issues which were outside the scope of the issues of 'limited scrutiny' for which the case of appellant was selected under the CASS guidelines. 2. For that on the facts and in the circumstances ... case, the Ld. CIT(A) ought to have held that the AO was unjustified in examining those issues which were beyond the scope of 'limited scrutiny' and in that view of the matter the additions aggregating to Rs.93,37,525/-made

Muhammed Kutty Kayingil, Malappuaram vs. The ITO, Kozhikode

In the result, the assessee’s appeal is dismissed

ITA 68/COCH/2022[2017-18]Status: DisposedITAT Cochin31 Jan 2024AY 2017-18

Bench: Shri Sanjay Arora & Shri Manomohan Dasmohammed Kutty Kayingil Income Tax Officer Mousufa Nivas (International Taxation) Edappal P.O. Vs. Kozhikode Malappuram 679576 [Pan:Cbxpm7315J] (Appellant) (Respondent)

For Appellant: NoneFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R

Section 115BSection 143(3)Section 69A

assessee, a non-resident Indian maintaining a NRE account, returned his income for the year at Rs.33,730/-. The same was selected for limited scrutiny in view of large cash deposits in his bank Mohammed Kutty Kayingil v. ITO account during the demonetisation period, i.e., from 09/11/2016 to 31/12/2016

Radesh Chand Sharma, Jaipur vs. Income Tax Officer Ward 6(2), Jaipur

ITA 807/JPR/2023[2014-15]Status: DisposedITAT Jaipur31 Jan 2024AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), DR MITHA LAL MEENA (Accountant Member)

For Appellant: Shri Deepak Sharma, CAFor Respondent: Mrs. Monisha Choudhary, Addl CIT-DR

Section 142(1)Section 143(1)(a)Section 143(2)Section 56(2)(vii)

income of Rs.4,03,440/-. The return was processed u/s 143(1)(a) of the Act. The case of the assessee was selected for Limited Scrutiny and notice u/s 143(2) of the Act was issued on 28-08-2015. Notice u/s 142(1)of the Act was issued alongwith

Gita, Bharatpur vs. ITO, Ward-2, Bharatpur

ITA 619/JPR/2023[2016-17]Status: DisposedITAT Jaipur31 Jan 2024AY 2016-17

For Appellant: Shri Tarun Mittal, CAFor Respondent: Mrs. Monisha Choudhary, Addl. CIT

Section 139(4)Section 69A

Return filed after 07.11.2016 and cash deposit during demonetization period." It is submitted that making additions on the issue other than recorded for limited scrutiny without following the procedure for conversion of limited scrutiny to the fully complete scrutiny as prescribed by CBDT is bad in law and thus ... announcement of Demonetization cannot be deemed to have been a planned affair, therefore addition of Rs.8,50,000/- being outside the scope of limited scrutiny deserves to be deleted. 3 On the facts and in the circumstances of the case and in law, the ld. CIT(A) has further erred

Shri. B.L. Nagendra Prasad, Bengaluru vs. Income-Tax Officer, Ward-5(2)(3), Bengaluru

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

ITA 1045/BANG/2023[2017-18]Status: DisposedITAT Bangalore31 Jan 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2017-18

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Shri Subramanian .S, JCIT DR

Section 115BSection 250Section 69A

return of income on 29.06.2017 vide e-filing acknowledgment No: 833249540290617 declaring a total income of Rs.12,68,970/-. The return was selected for Limited Scrutiny through CASS, notice u/s 143(2) of the Income Tax Act, 1961 was issued on 13.08.2018 and one more notice

Keshav Kumar Agarwal, Hyderabad vs. Income Tax Officer, Ward-6 (1), Hyderabad

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

ITA 30/HYD/2024[2017-18]Status: DisposedITAT Hyderabad30 Jan 2024AY 2017-18

Bench: Shri Laliet Kumarassessment Year: 2017-18 Keshav Kumar Agarwal, Vs. The Income Tax Officer, 6-3-1089/A/1/502, Ward-6(1), Harmony Heights, Hyderabad. Rajbhavan Road, Hyderabad. Telangana. Pan : Abqpa4260R (Appellant) (Respondent) Assessee By: Shri S.K. Gupta, Advocate. Revenue By: Shri Aravindakshan, Sr.Ar Date Of Hearing: 30/01/2024 Date Of Pronouncement: 30/01/2024

For Appellant: Shri S.K. Gupta, AdvocateFor Respondent: Shri Aravindakshan, SR.AR

Section 143(2)Section 143(3)Section 271ASection 69A

income for A.Y 2017-18 on 21.09.2017 admitting income from House Property Business & Other sources" at Rs.5,39,110/-. This case was selected for limited scrutiny under CASS on 26.09.2018 and the necessary statutory notices u/s 143(2) and 142(1) were issued through ITBA module to the registered mail

Apurva Sarin, Delhi vs. Assistant Commissioner of Income-Tax, Circle-3(3)(1), Bangalore

In the result, appeal of the assessee is partly allowed for

ITA 1049/BANG/2023[2017-18]Status: DisposedITAT Bangalore29 Jan 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Section 131Section 142(1)Section 142ASection 143(2)Section 143(3)Section 234BSection 250Section 50C

deduction of Rs. 1,60,000/-, arriving at a total income of Rs. 2,38,71,450/-. Subsequently, case was selected for 'Limited' scrutiny through CASS to verify: " Sale consideration of property shown in ITR is less than the value as per stamp authority as per return." 2.1 Notices

Apple Lifecare India Pvt Ltd, Mumbai vs. Income Tax Officer, Mumbai

In the result, the appeal of the assessee is allowed

ITA 3099/MUM/2023[2016-2017]Status: DisposedITAT Mumbai29 Jan 2024AY 2016-2017

Bench: Shri Aby T. Varkey, Jm & Shri Amarjit Singh, Am आयकर अपील सं/ I.T.A. No.3099/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2016-17) Apple Lifecare India Pvt. बिधम/ Ito-9(1)(3) Ltd. Aaykar Bhavan, Vs. 39, Nanoghanshyam, Iondl Maharishi Karve Road, Estate, Mahakali, Caves Mumbai-400020. Road, Andheri East, Mumbai-400093. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aabcd9736A (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Ms. Mona Makwana Revenue By: Shri Manoj Kumar Sinha (Sr. Dr) सुनवाई की तारीख / Date Of Hearing: 11/01/2024 घोषणा की तारीख /Date Of Pronouncement: 29/01/2024 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Company Against The Order Of The Ld. Cit(A)/Nfac, Delhi Dated 08.06.2023 For Ay 2016- 17. 2. The Grounds Of Appeal Of The Assessee Are As Under: -

For Appellant: Ms. Mona MakwanaFor Respondent: Shri Manoj Kumar Sinha (Sr. DR)

Section 68

filed its return of income for the relevant AY. 2016-17 declaring total income of Rs.4,08,340/-. Later the case was selected for limited scrutiny under CASS and accordingly, the AO issued notices. And in response to the notices, the Ld. AR of the assessee appeared and filed

DCIT, Central Circle-29, Delhi vs. Rita Chandiok, Delhi

In the result, the appeal of the Revenue is dismissed

ITA 908/DEL/2022[2016-17]Status: DisposedITAT Delhi29 Jan 2024AY 2016-17

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaassessment Year: 2016-17 Dcit, Vs Rita Chandiok Central Circle-29, L-41, Connaught Circus, New Delhi. Connaught Place, New Delhi – 110 001. Pan: Aaapc2224L (Appellant) (Respondent) Assessee By : Shri Vinod Bindal, Ca & Ms Rinky Sharma, Itp Revenue By : Shri Vivek Vardhan, Sr. Dr Date Of Hearing : 19.01.2024 Date Of Pronouncement : 29.01.2024 Order Per Anubhav Sharma, Jm:

For Appellant: Shri Vinod Bindal, CA &For Respondent: Shri Vivek Vardhan, Sr. DR

referred to as the Ld. AO). 2. The facts, in brief, are that the ld. AO while examining the case of the assessee under limited scrutiny had questioned the return of the assessee for the following two reasons: (i) new foreign asset in the nature of financial interest

Rugby Regency P.Ltd, New Delhi vs. Addl. CIT, Range-21, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 653/DEL/2019[2015-16]Status: DisposedITAT Delhi25 Jan 2024AY 2015-16

Bench: N.K. Billaiya & Ms. Astha Chandraasstt. Year: 2015-16 M/S. Rugby Regency P. Ltd. Vs. Addl. Cit, 37-Ring Road, Range-21, Lajpat Nagar-Iv, New Delhi. New Delhi – 110 024 Pan Aagcr5908K (Appellant) (Respondent)

For Appellant: Shri R.S. Singhavi, CAFor Respondent: Shri P.N. Barnwal, CIT-DR

Section 143(3)Section 32Section 56(2)(viib)

assessee e-filed its return on 29.09.2015 declaring loss of Rs. 21,29,69,144/-. The case was selected for limited scrutiny. Statutory notice(s) along with questionnaire were issued and served upon the assessee. In response, requisite information / details were filed. The Ld. Assessing Officer (“AO”) completed the assessment

Shri Vivekkumar Bha vs. Ar, Mehsanavs.the ITO, Ward-5(2)(1), Ahmedabad

In the result, the appeal filed by the Assessee is allowed for statistical purpose

ITA 86/AHD/2022[2017-18]Status: DisposedITAT Ahmedabad24 Jan 2024AY 2017-18

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 143(2)Section 144Section 69Section 69A

Year 2017-18, the assessee filed his Return of Income on 05.08.2017 declaring total income of Rs.2,05,970/-. The return was selected for limited scrutiny since large cash deposits made during demonetization period and the Business return filed for the first time. Accordingly notice u/s. 143(2) was issued

Panexcell Clinical Lab Private Limited, Mumbai vs. Asstt. Commissioner of Income Tax Holding Charges of Income Tax Officer 18(2)(4), Mumbai

ITA 1215/MUM/2023[2015-2016]Status: DisposedITAT Mumbai24 Jan 2024AY 2015-2016

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Hari RahejaFor Respondent: Shri H.M. Bhatt

Section 143(2)Section 143(3)Section 234ASection 271(1)(c)Section 37(1)

read with Circular dated 08/09/2010, Instruction dated 02/09/2014, 26/09/2014, and 14/07/2016, issued by the CBDT in respect of cases selected under CASS and for Limited scrutiny. (4) On the facts and in the circumstances of the case and in law the Assessing Officer was not justified in making an assessment

Vaaan Infra Private Limited, Haryana vs. Pr, CIT Delhi-7, Delhi

ITA 1102/DEL/2022[2015-16]Status: DisposedITAT Delhi24 Jan 2024AY 2015-16

Bench: PCIT, Delhi-9, however the order passed by Hon'ble PCIT, Delhi-7 on 30.03.2021.

Section 263Section 56(2)(vib)Section 56(2)(viib)Section 56(25)(viib)

allowing the Appeal. 6. Per contra, the Ld. Departmental Representative vehemently submitted that though the case of the assessee was initially selected for limited scrutiny to verify the ‘large share premium received during the year’, the A.O. has not examined the said issue, the A.O. has only concentrated

Shri Babubhai Bhimajibhai Mali, Ahmedabad vs. The ITO, Ward-1(2)(1), Ahmedabad

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

ITA 171/AHD/2022[2014-15]Status: DisposedITAT Ahmedabad23 Jan 2024AY 2014-15

Bench: Shri Ramit Kochar & Ms. Suchitra Kambleassessment Year : 2014-15 Shri Babubhai Bhimajibhai The Ito Mali V. Ward-1(2)(1) 120, M.G. Market, Ahmedabad-380015 Shanti Commercial Centre Gujarat Nagar Sheth Ho Vando Gheekanta Ahmedabad – 360 001 Gujarat Pan:Aappm 7611 N अपीलाथ"/ (Appellant) अपीलाथ" "" यथ" "" य थ"/ (Respondent) अपीलाथ" अपीलाथ" "" य "" य थ" थ" Assessee By : Shri Prashant Shrivastav, Ca Revenue By : Shri Vipul Chavda,Sr. Dr

For Appellant: Shri Prashant Shrivastav, CAFor Respondent: Shri Vipul Chavda,Sr. DR

Section 144Section 250Section 253(3)Section 44ASection 57Section 69C

assessment year 2014-15 on 29/03/2016 declaring income at Rs.4,29,105/-. The case was selected for framing scrutiny assessment under CASS under limited scrutiny. The Assessing Officer passed the assessment order u/s.144 of the I.T. Act, 1961 dated 30/12/2016, wherein income of the assessee was assessed at Rs.1

Lalabhagat Limbabhagat Sanya, Bhavnagar vs. The Income Tax Officer, Ward-1(4), Bhavnagar

Appeal of the assessee is partly allowed for statistical purposes

ITA 969/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad19 Jan 2024AY 2017-18

Bench: Ms. Suchitra R. Kambleassessment Year: 2017-18 Lalabhagat Limbabhagat Sanya, Vs Income Tax Officer, Plot No. 2541, City Ring Road, Ward-1(4), Opp. Talaja Jakatnaka, Bhavnagar, Bhavnagar Gujarat-364001 Pan : Ahups 1013 Q अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Parimalsinh B. Parmar, Ar Revenue By : Shri Purushottam Kumar, Sr Dr सुनवाई की तारीख/Date Of Hearing : 10/01/2024 घोषणा की तारीख /Date Of Pronouncement : 19/01/2024

For Appellant: Shri Parimalsinh B. Parmar, ARFor Respondent: Shri Purushottam Kumar, Sr DR

Section 142(1)Section 143(2)Section 144Section 234ASection 250Section 270ASection 271ASection 271FSection 272A(1)(d)Section 69A

appreciating the facts and law in their proper perspective.” 3. The case of the assessee was selected for scrutiny under the CASS Module for limited scrutiny due to cash deposit during the demonetization period as the assessee had deposited cash of Rs.12,09,500/- in multiple bank accounts with Central ... speed post as well as through email informing that the return of income filed by the assessee on 18.07.2017 has been selected for limited scrutiny. Thereafter, notice u/s 142(1) of the Act dated 31.05.2019 with detailed questionnaire was issued and served upon the assessee. Final show-cause notice