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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Satish Nagesh Kulkarni, Secunderabad vs. DCIT., Circle-10(1), Hyderabad

ITA 1025/HYD/2025[2016-17]Status: DisposedITAT Hyderabad13 Jan 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1025/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Satish Nagesh Kulkarni, Vs. Dcit, Secunderabad. Circle-10(1), Pan: Begpk9791B Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: None राज" व "ारा/Revenue By: Shri K. Vinoth Kannan, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 06/01/2026 घोषणा की तारीख/Date Of 13/01/2026 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 06/01/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 29/12/2018 For The Assessment Year (Ay) 2016-17. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal Before Us:

For Appellant: NoneFor Respondent: Shri K. Vinoth Kannan, Sr
Section 133(6)Section 143(3)Section 68

income for AY 2016-17 on 31/01/2017, declaring an income of Rs. 21,51,940/-. Thereafter, the case of the assessee was selected for “limited scrutiny” under CASS to verify whether the cash deposit has been made from disclosed sources. During the course of the assessment proceedings, the AO observed ... Individual filed return of income for the A.Y. 2016-17 on 03.01.2017 declaring total income of Rs.21,51,940/-. The case was selected for limited scrutiny under CASS to examine ‘whether the cash deposits made during the year are from disclosed sources’. The Ld. AO issued notice

Srirangarao Nadipallly, Karimnagar vs. ACIT., Circle-1, Karimnagar

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

ITA 844/HYD/2025[2016-17]Status: DisposedITAT Hyderabad09 Jan 2026AY 2016-17

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.844/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Shri Srirangarao Nadipally Vs. Assistant Commissioner Karimnagar Of Income Tax Pan:Acbpn3816E Circle-1, Karimnagar (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Adv. Kvssn Kumar राज" व "ारा/Revenue By: Sankar Pandi P - Sr. Dr सुनवाई की तारीख/Date Of Hearing: 05/01/2026 घोषणा की तारीख/Pronouncement: 09/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Srirangarao Nadipally (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 24.03.2025 For The A.Y 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Adv. KVSSN KumarFor Respondent: Sankar Pandi P - Sr. DR
Section 143(2)Section 143(3)

submitted that the assessment for Assessment Year 2015–16 was Page 6 of 14 ITA No 844 of 2025 Srirangarao Nadipally initially selected for limited scrutiny and therefore, it cannot be presumed that the cash balance shown by the assessee as on 31.03.2015 was examined or accepted ... relevant portion of which is to the following effect: 9. On perusal of above, we find that although the case was initially selected for limited scrutiny, the same was subsequently converted into complete scrutiny. Despite such complete scrutiny, no adverse observation has been recorded by the Ld. AO with respect

Saurashtra Cement Limited, Porbandar vs. The Principal Commissioner of Income Tax, Jamnagar

In the result, appeal filed by the assessee is allowed

ITA 307/RJT/2024[2018-19]Status: DisposedITAT Rajkot08 Jan 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.307/Rjt/2024 िनधा"रणवष"/ Assessment Year: 2018-19 Saurashtra Cement Ltd. Principal Commissioner Of Near Railway Station, बनाम Income Tax, Jamnagar, Saurashtra Cement Factory, Jamnagar Vs. P.O. Ranavav, Adityana Road, Porbandar, Gujarat-360560 Pan : Aahfs5211J (अपीलाथ"/Assessee) : (""थ"/Respondent) िनधा"रती की ओर से/Assessee By : Shri Vimal Desai, Ld.Ar राज" की ओर से/Revenue By : Shri Sanja Punglia, Ld. Cit-Dr सुनवाई की तारीख/Date Of Hearing : 16/10/2025 घोषणा की तारीख/Date Of Pronouncement : 08/01/2026 Order

For Appellant: Shri Vimal Desai, ld.ARFor Respondent: Shri Sanja Punglia, Ld. CIT-DR
Section 143(3)Section 14ASection 263Section 36(1)(iii)

interest in respect of capital borrowed, as these were not subject matter of verification before the A.O. under the limited scrutiny is not permissible as the order sought to be revised cannot be erroneous or prejudicial to the interest of revenue. About disallowance u/s. 14A r.w.r. 8D in respect ... sake of brevity. Learned DR for the revenue also submitted that assessee`s case was selected for complete scrutiny and not for limited scrutiny, therefore, there is no findings in the assessment order that assessing officer has examined these issues which were raised by the learned PCIT, therefore order passed

Late Madan Lal Gupta Through Legal Heir Abhishek Gupta, Barabanki vs. ITO Ward 5(4), Barabanki-1, Barabanki

In the result, the appeal of the assessee stands allowed

ITA 437/LKW/2025[2017-18]Status: DisposedITAT Lucknow07 Jan 2026AY 2017-18

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Late Madan Lal Gupta V. Ito Through Legal Heir Ward 5(4) Abhishek Gupta Barabanki - 1 367, Qanoon Goyan Nawabganj, Barabanki U.P) Tan/Pan:Acepg5468Q (Applicant) (Respondent) Applicant By: Shri Gaurav Gupta, C.A. Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 25.05.2025, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2017-18. 2.0 The Brief Facts Of The Case Are That The Assessee Was A Retired Assistant Engineer In The U.P. Power Corporation, Drawing Pension. The Assessee E-Filed His Return Of Income For The Year Under Consideration On 27.07.2017 Declaring A Total Income Of Rs.4,78,310/- After Claiming A Deduction Under Chapter Vi-A, Amounting To Rs.1,50,000/-. The Case Of The Assessee Was Selected For Limited Scrutiny Under The Computer Aided Scrutiny Selection (Cass) For The Reason Of ‘Cash Deposit During The Demonetization Period’. Accordingly, A Notice Under Section 143(2) Of The Income Tax Act, 1961 (Hereinafter Called

For Respondent: Shri R.R.N. Shukla, D.R
Section 115BSection 142(1)Section 143(2)Section 143(3)Section 69A

Rs.4,78,310/- after claiming a deduction under Chapter VI-A, amounting to Rs.1,50,000/-. The case of the assessee was selected for limited scrutiny under the Computer Aided Scrutiny Selection (CASS) for the reason of ‘Cash deposit during the demonetization period’. Accordingly, a notice under section ... well as NFAC, by raising the following grounds of appeal: 1.1. The Ld. AO has erred in making an addition beyond the scope of limited scrutiny, which was confined to cash deposits during the demonetization period only as the final addition made includes cash deposits pertaining to the entire year

Income Tax Officer, Ward 5, Sangli. vs. Shree Ganesh Nagari Sahakari Pat Sanstha Maryadit, Ashta

In the result, the appeal filed by the Revenue is dismissed

ITA 2375/PUN/2025[2018-19]Status: DisposedITAT Pune06 Jan 2026AY 2018-19

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2375/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Ito, Ward-5, Sangli. Vs. Shree Ganesh Nagari Sahakari Pat Sanstha Maryadit, Ashta, Tal. Walwa, Dist. Sangli, Sangli- 416301. Pan : Aaaas8248R Appellant Respondent C. O. No.49/Pun/2025 (Arising Out Of Ita No.2375/Pun/2025) िनधा"रण वष" / Assessment Year : 2018-19 Shree Ganesh Nagari Vs. Ito, Ward-5, Sangli. Sahakari Pat Sanstha Maryadit, Ashta, Tal. Walwa, Dist. Sangli, Sangli- 416301. Pan : Aaaas8248R Appellant Respondent Revenue By : Shri Umesh Phade Assessee By : Shri Sarang Gudhate Date Of Hearing : 25.11.2025 Date Of Pronouncement : 06.01.2026 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Revenue Is Directed Against The Order Dated 05.08.2025 Passed By Ld. Cit(A)/Nfac For The Assessment

For Appellant: Shri Sarang GudhateFor Respondent: Shri Umesh Phade
Section 143(3)Section 28Section 36(1)(va)Section 80P(2)Section 80P(2)(d)

alleged ground that the said contribution was not deposited on or before the statutory due date. Which is beyond the scope of "Limited Scrutiny". 5. Under the facts and circumstances of the case and in law, Ld Assessing Officer has erred in issuing Notice of Demand without passing Assessment Order