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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Malco Energy Ltd., Mumbai vs. Asst CIT Circle-10(2)(2), Mumbai

ITA 7314/MUM/2019[2015-16]Status: DisposedITAT Mumbai13 Sept 2023AY 2015-16

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm Asst. Commissioner Of Income-Tax Malco Energy Limited Circle 10(2)(2), Vedanta House, Room No.209, 75, Nehru Road, Ville- 2Nd Floor, Parle, Vs. Mumbai-400 099 Aaykar Bhavan Maharashtra, India Maharishi Karve Road, Mumbai-400 020 (Appellant) (Respondent) Pan No. Aahcs6896A Assessee By : Ms. Fereshte Sethna, Shri Mrunal Parekh, Ars Revenue By : Shri Manoj Kumar, Cit Dr

For Appellant: Ms. Fereshte SethnaFor Respondent: Shri Manoj Kumar, CIT DR

Section 115J

loss as per the profit and loss account of ₹ 445,665,451. 5. This return of income [ROI] was picked up for limited scrutiny by issue of notice under section 143 (2) of the act on 12/4/2016. 6. Assessee has reported in Form No. 3CEB with its associated enterprises following

Shri Abdul Rashid Butt, Kishtwar vs. Deputy Commissioner of Income Tax Circle-I, Jammu

In the result, the appeal of the assessee bearing ITA No

ITA 144/ASR/2022[2018-19]Status: DisposedITAT Amritsar13 Sept 2023AY 2018-19

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 144BSection 250Section 68

made by the Ld. AO u/s. 68 in spite of the fact that complete details of increase in capital on basis of which the limited scrutiny was initiated were provided to the AO. 4. That learned CIT (A) has erred in law and facts and circumstances of the case

Shri Amritpal Singh (Prop), Jalandhar vs. Principal Commissioner of Income Tax- 1, Jalandhar

In the result, appeal of the assessee ITA No

ITA 425/ASR/2019[2014-15]Status: DisposedITAT Amritsar13 Sept 2023AY 2014-15

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 110Section 263Section 54D

made. However, we find that it is not a case wherein no inquiries were made by Ld. AO. Rather the case was selected for limited scrutiny to examine and verify three I.T.A. No. 425/Asr/2019 18 Assessment Year: 2014-15 aspects which were duly examined and verified by Ld. AO. Secondly

Shri Rakesh Sadana, Jalandhar vs. Income Tax Officer Ward1(3), Jalandhar

In the result, the appeal of the assessee bearing ITA No

ITA 202/ASR/2018[20014-15]Status: DisposedITAT Amritsar13 Sept 2023

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(1)Section 143(3)Section 144Section 250

demand of Rs. 1,05,160/-was created. Subsequently, the case was selected for limited scrutiny for the reasons of “Large amount of sundry creditors”. During the course of assessment proceedings, the assessing officer afforded several opportunities on various occasions to the assessee to furnish complete postal addresses in respect

DCIT-CC-27, New Delhi vs. Anshika Consultants Pvt Ltd., New Delhi

In the result, Appeal of the Revenue is partly allowed for

ITA 35/DEL/2022[2015-16]Status: DisposedITAT Delhi13 Sept 2023AY 2015-16

Bench: Or At The Time Of Hearing Of The Appeal.” Cross Objection

Section 115JSection 136(6)Section 143(3)Section 14ASection 68

before or at the time of hearing of the appeal.” Cross Objection That in the absence of permission from the higher authority to convert limited scrutiny selected in CASS into full scrutiny, the Assessing Officer has no jurisdiction to frame assessment u/s 143(3) of IT Act under full scrutiny ... Revenue preferred the above appeal in ITA No.35/Del/2022 and challenging the action of the A.O. in converting the ‘limited scrutiny’ into ‘full scrutiny’ and by challenging the jurisdiction to frame the assessment order Page 3 of 33 ITA No.35/Del/2022 & CO No.76/Del/2023 DCIT vs. Anshika Consultants

7 Horses Hospitality LLP, Jaipur vs. Income Tax Officer, Ward 1(1) Jaipur, Jaipur

In the result, all the three appeals of the assessee in ITA No

ITA 332/JPR/2023[2019-20]Status: DisposedITAT Jaipur13 Sept 2023AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Sharwan Kumar GuptaFor Respondent: Ms. Monisha Choudhary, Addl. CITa

Section 143(1)Section 143(1)(a)Section 36(1)(va)Section 43B

cannot go beyond the reasons 15 7 HORSES HOSPITALITY LLP VS ITO, WARD 1 (1), JAIPUR for scrutiny selection and such 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

Afroz Dil Khan, Udaipur vs. ITO, Ward-1(1), Udaipur

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

ITA 72/JODH/2022[2017-18]Status: DisposedITAT Jodhpur12 Sept 2023AY 2017-18

Bench: The Final Hearing, If Necessary.”

Section 115BSection 142(1)Section 143(1)Section 143(2)Section 144Section 36(1)(va)Section 44ASection 69A

44AD. The return was processed on 17.03.2018 u/s 143(1) of the I.T. Act, 1961. The case was selected through CASS for limited scrutiny. Accordingly, a notice u/s 143(2) of the I.T. Act, 1961 was issued on 09.08.20189 fixing hearing for 17.08.2018, which was duly served upon the assessee

Syed Nadeem Abbas, Delhi vs. ITO, Ward-28(4), New Delhi

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

ITA 114/DEL/2023[2016-17]Status: DisposedITAT Delhi11 Sept 2023AY 2016-17

Bench: Shri C.M. Garg & Shri Girish Agrawalassessment Year: 2016-17

For Appellant: Shri Sachin Jain, AdvsFor Respondent: Shri Anuj Garg –SR. DR

Section 144

pate. In the return filed by the assessee, he had claimed agricultural income of Rs.50,20,892. Case of the assessee was selected for limited scrutiny under CASS on the issue of “large agricultural income”. Since, no documentary evidences were furnished in this respect, this was added as income from

Abhinandan Kedia, Janjgir-Champa vs. Principal Commissioner of Income Tax, Raipur-1, Raipur

In the result appeal of the assessee is allowed in terms of our observations herein above

ITA 174/RPR/2023[2018-19]Status: DisposedITAT Raipur11 Sept 2023AY 2018-19

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.174/Rpr/2023 िनधा"रण वष" /Assessment Year: 2018-19

For Appellant: Shri S.R.Rao, AdvFor Respondent: Shri Debashish Lahiri, CIT DR

Section 143(2)Section 143(3)Section 263

CASS for clarification identifying the limited issues. 8. Though the word "initially" is mentioned in para-2, the issues are specified. Hence, this is limited scrutiny. 9. The ld. Pr.CIT cannot enlarge the scope in revision proceedings. 10. Secondly, during sec. 263 proceedings appellant filed all particulars and evidences clearly ... basis for invoking the provisions of sections 263 for revision of the assessment were show caused and responded by the assessee. Issue pertaining to Limited scrutiny was found to be misunderstood by the assessee and thus was clarified by the Ld PICT. On merits, the Ld PCIT was found

ITO- 5(1)(1), Mumbai vs. M/S. Bkc Abode Pvt. Ltd., Mumbai

In the result, the appeal of the learned Assessing Officer is dismissed

ITA 1587/MUM/2023[2018-19]Status: DisposedITAT Mumbai08 Sept 2023AY 2018-19

Bench: Shri Prashant Maharishi, Am & Mskavitha Rajagopal, Jm M/S Bkc Abode Pvt. Ltd. Income Tax Officer 394-C, Lamington Ward 5(1)(1), Chambers, 570, 5Th Floor, Lamington Road, Vs. Aaykar Bhavan, Grant Road, Mumbai-400 020 Mumbai-400 004 (Appellant) (Respondent) Pan No. Aaecb3807D Assessee By : Shri K.P. Devani, Adv. Revenue By : Shri S Srinivasu, Cit Dr Date Of Hearing: 05.09.2023 Date Of Pronouncement : 08.09.2023

For Appellant: Shri K.P. Devani, AdvFor Respondent: Shri S Srinivasu, CIT DR

Section 115BSection 143Section 143(1)Section 143(3)Section 154Section 68

Abode Pvt. Ltd; A.Y. 18-19 04. Subsequently, the return of income was picked up for scrutiny under e-assessment scheme, 2019 for limited scrutiny assessment for verification of share capital in the company. The learned Assessing Officer found that assessee does not have any income for this year

Chomansingh M. Deora, Mumbai vs. PCIT-19, Mumbai

In the result, the appeal by the assessee is dismissed

ITA 401/MUM/2023[2017-18]Status: DisposedITAT Mumbai07 Sept 2023AY 2017-18

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Bhupendra ShahFor Respondent: Shri K.C. Selvamani

Section 142(1)Section 143(2)Section 263Section 57

filed its return of income on 29/09/2017, declaring a total income of Rs.46,56,450. The return filed by the assessee was selected for limited scrutiny assessment via CASS and statutory notices under section 143(2) as well as section 142(1) of the Act were issued and served ... forming part of the paper book from pages 29-30, the return filed by the assessee was selected for limited scrutiny for examination of the following issues:- (a) Salary income (b) Deduction against income from other sources 14. During the assessment proceedings, notice dated 23/10/2019, was issued under section

Pareshkumar Lakhmichand Muthreja, Mumbai vs. The Income Tax Officer, International Taxation -Ward 3(2)(1), Mumbai

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

ITA 977/MUM/2023[2017-18]Status: DisposedITAT Mumbai06 Sept 2023AY 2017-18

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Rahul Chaudhary, Hon'Blepareshkumar Lakhmichand Muthreja V. Income Tax Officer 304, Venkatesh Chambers Chs International Taxation – 3(2)(1) Prescot Road, G.T. Marg Room No. 1627, 16Th Floor Fort, Mumbai - 400001 Air India Building Nariman Point, Mumbai – 400 021 Pan: Aacpm5882C (Appellant) (Respondent)

Section 133(6)Section 143(2)Section 69

case are, assessee filed return of income for A.Y.2017-18 on 27.11.2017 declaring income of ₹.3,32,170 /-. The case was selected for limited scrutiny for the reason "Large value of cash deposited during demonetization period as compared to returned income". Accordingly, notices

ADIT Infrapower & Multitrading Pvt Ltd, New Delhi vs. Pr. CIT, Gurgaon

In the result, the appeal of the assessee is dismissed

ITA 4944/DEL/2019[2014-15]Status: DisposedITAT Delhi05 Sept 2023AY 2014-15

Bench: Sh. C. M. Gargdr. B. R. R. Kumarita No. 4944 /Del/2019 : Asstt. Year : 2014-15 Adit Infrapower & Multitrading Pvt. Vs Pcit, Ltd., Da-08, 2Nd Floor, Vikas Marg, Gurgaon Shakarpur, New Delhi-110092 (Appellant) (Respondent) Pan No. Aahca5582H Assessee By : None Revenue By : Sh. P. Praveen Sidharth, Cit Dr Date Of Hearing: 10.08.2023 Date Of Pronouncement: 05.09.2023 Order Per Dr. B. R. R. Kumar:

For Appellant: NoneFor Respondent: Sh. P. Praveen Sidharth, CIT DR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 263

case was processed u/s 143(1) of the Income Tax Act, 1961, accepting the returned income as such. The case was selected under Limited Scrutiny under CASS. Accordingly, statutory notice u/s 143(2) was issued on 18.09.2015. Limited questionnaire alongwith notice u/s 142(1) was issued to the assessee

Anand Infracon, Raipur vs. Principal Commissioner of Income Tax, Raipur-1, Raipur

In the result, the assessee's appeal is allowed regarding our observations above

ITA 100/RPR/2023[2018-19]Status: DisposedITAT Raipur04 Sept 2023AY 2018-19

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.100/Rpr/2023 "नधा"रण वष" / Assessment Year : 2018-19 Anand Infracon 502, Dhebar Arcade, Near Kundan Palace, Raipur-492 001 (C.G.) Pan : Aatfm4011A .......अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax, Raipur-1 (C.G.) ……""यथ" / Respondent

For Appellant: Shri Praveen Jain, CAFor Respondent: Smt. Ila M. Parmar, CIT-DR

Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 36(1)(va)Section 4(7)

issues which were never the part of assessment framed u/s 143(3) of I.T. Act 1961 completed based on limited scrutiny is bad in law. 3 Anand Infracon Vs. Pr. CIT, Raipur-1 6. Ground 6: The learned Principal CIT-I, Raipur had no jurisdiction ... dated 01.10.2019 had been approved by the A.O; and (iii) now when the case of the assessee was selected for limited scrutiny assessment u/s.143(2) of the Act, i.e., for verifying “large payments made under section 194C to persons to have not filed return of income”, therefore

Lalit Vithaldas Panchal, Mumbai vs. ITO Ward-29(2)(2), Mumbai

ITA 1355/MUM/2023[2016-2017]Status: DisposedITAT Mumbai31 Aug 2023AY 2016-2017

For Appellant: Shri Shashank Mehta, A.RFor Respondent: Shri B. Laxmi Kanth, D.R

Section 250Section 68

consideration and adjudication of the issues at hand are : assessee's return of income declaring total income of Rs.4,40,360/- was subjected to limited scrutiny for the reasons "large cash deposited in savings bank account and the assessee has also transferred one or more properties during the year under

Aman Growth Fund Pvt Ltd, New Delhi vs. Pr.CIT, Delhi

In the result, the appeal of the assessee is allowed

ITA 659/DEL/2021[2015-16]Status: DisposedITAT Delhi31 Aug 2023AY 2015-16

Bench: Sh. G.S.Pannu, Hon’Ble & Sh.Anubhav Sharmaita No. 659/Del/2021, A.Y. 2015-16 M/S. Aman Growth Fund Vs. Pr. Cit(Central), Private Limited Delhi-2 L-4, Green Park Extension New Delhi Pan : Aaaca0525B Appellant Respondent

Section 142(1)Section 143Section 143(3)Section 263Section 56Section 56(2)(viib)

failed to make the inquiries and based on information available. Ld. AO should have expanded the scope of assessment to convert the limited scrutiny into complete scrutiny. Accordingly, Ld. PCIT had directed the ld. AO to make fresh assessment keeping in mind the observations. 3. At the time of hearing ... crores in the said order. • That most importantly the ld. PCIT failed to appreciate that the AO had carried out a due inquiry within limited scrutiny parameters which reflected application of mind and hence the PCIT had no jurisdiction in passing a de novo assessment order as per settled

Shri Vinayak Sudhakar Malkotagi, Mumbai vs. ITO. Int Taxation Ward-3(2)(1), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 549/MUM/2023[2020-21]Status: PendingITAT Mumbai30 Aug 2023AY 2020-21

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blevinayak Sudhakar Malkotagi V. Ito – International Taxation Flat No. 104, Plot No. 36 Ward – 3(2)(1) Gorai Shree Sahyog Chs 16Th Floor, Air India Building Nariman Point, Mumbai – 400 021 Near Gorai Depot Borivali (W), Mumbai - 400091 Pan: Aqopm5908M (Appellant) (Respondent)

Section 10(1)Section 143(2)Section 144C(5)Section 2

filed his original return of income for A.Y. 2020-21 on 02.01.2021 declaring income of ₹.2,77,560/-. Thereafter, the return was selected for limited scrutiny for the reason of 'Agricultural Income'. Notices u/s 143(2) and 142(1) of the Act along with questionnaire were issued and served

Rivet Electricals Pvt Ltd, Delhi vs. Pr.CIT- Faridabad, Faridabad

The Appeal of the assessee stands allowed

ITA 1885/DEL/2022[2015-16]Status: DisposedITAT Delhi30 Aug 2023AY 2015-16

Bench: Initiating The Proceeding As No Enquiry Was Made By Pr. Cit In Arriving At Conclusion Which Is Contrary In View Of The Jurisdictional & Other High Courts & The Apex Court. D. That Once The Sums Have Been Received Through Banking Channels & Complete Evidences Was Provided During The Course Of The Assessment, Suspicion Raised Purely On Assumptions Is Wholly Unsustainable In Law.

Section 143(1)Section 143(3)Section 263

filed returned declaring income of Rs. 1,78,430/- the same was processed u/s 143(1) of the Act, subsequently case was selected for limited scrutiny and an order u/s 143(3) of the Act came to be passed accepting the returned income. Vide order dated 28/08/2019 an order

Mrs Indu Bala Sanghvi, Jhabua vs. The ITO, Jhabua

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

ITA 114/IND/2023[2017-18]Status: DisposedITAT Indore30 Aug 2023AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanimrs. Indu Bala Sanghvi Ito 1,1 Ramkrashan Nagar Jhabua Vs. Jhabua (Appellant / Assessee) (Respondent/ Revenue) Pan: Bmzps 0243 R Assessee By None Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 28.08.2023 Date Of Pronouncement 28.08.2023

Section 250Section 250(6)

Copy of Press release enclosed as annexure-1. 2. That the Learned CIT (A) also ignoring the fact that the case was selected for limited scrutiny through CASS on the basis of cash deposit during the demonetization period. As per the information on AIMS module and ITS in 360 Degree

Smt. Trushaba C. Manek L/H. of Late. Shri Chandrasinh P. Manek (Properitor of Dwarkesh Enterprise), Okha, Dist. Jamnagar vs. The Pr. CIT, Jamnagar

In the result, the appeal of the assessee is allowed

ITA 91/RJT/2021[2015-16]Status: DisposedITAT Rajkot29 Aug 2023AY 2015-16

Bench: Mrs. Annapurna Gupta & Mrs. Madhumita Roy(Through Web-Based Video Conferencing Platform) िनधा"रणवष"/Assessment Year: 2015-16 Mrs. Trushaba C. Manek, Vs. Principal Commissioner Of L/H. Of Late Shri Chandrasinh P. Income-Tax, Manek (Prop. Of Dwarkesh Jamnagar Enterprise), Bazar Lane, Raghunath Road, Okha, Gujarat Pan : Aijpm 0949 F अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Dushyant Maharshi, Ar Revenue By : Shri Shramdeep Sinha, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 22.08.2023 घोषणा क" तारीख /Date Of Pronouncement: 29.08.2023 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Learned Principal Commissioner Of Income-Tax, Jamnagar [Hereinafter Referred To As “Pcit”] Dated 30.03.2021, In Exercise Of His Revisionary Powers Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], For The Assessment Year 2015-16. 2. The Assessee Has Raised The Following Grounds:- “1. Hon'Ble Pr. Cit Had Issued Notice U/S. 263 In The Name Of Deceased Person, Therefore Notice Issued U/S. 263 Is Not Valid In The Eyes Of Law & Hence Required To Be Quashed. 2. Hon'Ble Pr. Cit, Jamnagar Has Erred In Law & In Facts In Invoking His Revisionary Powers U/S. 263 Without Having Valid Jurisdiction For Addition Of Income U/S. 2(24)(X) R.W.S. 36(1)(Va) Of The Act For Epf For Rs. 8,35,800/- Whereas Case Was Selected For Limited Scrutiny On The Following Grounds:

For Appellant: Shri Dushyant Maharshi, ARFor Respondent: Shri Shramdeep Sinha, CIT-DR

Section 143(2)Section 143(3)Section 14ASection 2(24)(x)Section 263Section 36(1)(va)

income u/s. 2(24)(x) r.w.s. 36(1)(va) of the Act for EPF for Rs. 8,35,800/- whereas case was selected for Limited Scrutiny on the following grounds: 2 Trushaba C. Panek, L/h of Late Shri Chandrasinh P. Panek Vs. PCIT. AY : 2015-16 a) Contract Receipts/Fees Mismatch ... Credit Mismatch Hence, revision powers u/s. 263 of the IT Act cannot be invoked on the issues other than the limited grounds under limited scrutiny which were subject matter of Assessment Order u/s. 143(3) dated 31.08.2017. 3. Without prejudice to above ground, Hon'ble Pr. CIT, Jamnagar has erred