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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Yashoda Suresh Jadhav, Bandra East vs. Income Tax Officer, Palghar

In the result appeal of the assessee is partly allowed

ITA 4086/MUM/2024[2017-2018]Status: DisposedITAT Mumbai24 Dec 2025AY 2017-2018

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Yashoda Suresh Jadhav Income Tax Officer Ward 1 Palghar B/34/4 Near Hanuman Mandir Vs Maharashtra-401404 Bandra Government Colony Bandra East, Maharashtra-400051 [Pan:Aebpj2575A] Appellant / Assessee Respondent / Revenue

Section 115Section 115BSection 143(3)Section 254(1)Section 69A

assessee. We find that assessee while filing return of income has declared income of Rs. 5,67,520/-. Case was selected for limited scrutiny to verify cash deposit during demonetization. The assessing officer find that assessee has made cash deposit in three bank account as recorded in Para

BHA vs. Agar Dealers Pvt Ltd, Delhivs.ITO Ward-4(1), Delhi

In the result, appeal of the assessee in ITA No

ITA 2445/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Dec 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhan

Section 142(1)Section 143(1)Section 144Section 154Section 250Section 50C

income of Rs. 56,26,520/-. The said return was duly processed under section 143(1) of the Act. The case was selected for limited scrutiny by issuing statutory notice under section 142(1) of the Act which was duly served upon the assessee. The assessee company did not comply ... case are that the assessee filed its Return of Income on 29.09.2017 declaring an income of Rs. 56,26,520/-Return was selected for limited scrutiny assessment through CASS and accordingly, statutory notices were issued and served upon the assessee. The AO passed an order u/s 144 wherein he made

Himanshu Kukreja, Dehradun vs. ITO, Dehradun

In the result, Appeal of the Assessee is dismissed

ITA 147/DDN/2024[2016-17]Status: DisposedITAT Dehradun23 Dec 2025AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Himanshu Kukreja Vs Income Tax Officer Matta Garg & Co. Ca 15- Income Tax Office, 13-A, Astley Hall, Dehradun, Subhash Road, Dehradun, Uttarakhand Uttarakjhand Pan:Ahipk9462F Appellant Respondent Assessee By Sh. S. K. Matta, Ca Revenue By Sh. A. S. Rana, Sr. Dr Date Of Hearing 12/11/2025 Date Of Pronouncement 23/12/2025

Section 13(1)Section 143(3)Section 144BSection 263Section 56(2)Section 56(2)(vii)

order u/s 143(3) on 2.11.2018 accepting returned income of Rs. 10,02,000/-. The case of the Assessee was selected for scrutiny under 'limited scrutiny' to examine issue - whether investment and income relating to properties are duly disclosed. 3.1. Subsequently, the case was later taken up for revision

Deputy Commissioner of Income-Tax, Central Circle-1, Surat, Aayakar Bhawan, Majura Gate vs. Royal Developers, Nr. Ip Mission School, Muglisa

ITA 860/SRT/2024[2018-19]Status: DisposedITAT Surat23 Dec 2025AY 2018-19

For Appellant: Mr. Suresh K KabraFor Respondent: Shri Ajay Uke, Sr. DR

Section 143(3)Section 56(2)(x)Section 69Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL SURAT BENCH “DB” SURAT BEFORE SHRI SANDEEP GOSAIN (JUDICIAL MEMBER) AND SHRI OM PRAKASH

Nasim Ahmad Khan, Siddharthnagar vs. ACIT, Gonda- New

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

ITA 492/LKW/2024[2017-18]Status: DisposedITAT Lucknow23 Dec 2025AY 2017-18

Bench: Shri Kul Bharat & Shri Nikhil Choudharyआयकर अपील सं/ Ita No.492/Lkw/2024 ननिाारण वर्ा/ Assessment Year: 2017-18 Nasim Ahmad Khan V. The Asstt. Ward No.7, Subhash Nagar, Commissioner Of Income Shohratgarh, Siddharthnagar, Tax, Uttar Pradesh-272205. Gonda New 271003. Pan:Aigpk3776M अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कक और से/Appellant By: None प्रत्यर्थी कक और से /Respondent By: Shri R. R. N. Shukla, Addl. Cit(Dr) सुनवाई कक तारीख / Date Of Hearing: 26 11 2025 घोर्णा कक तारीख/ Date Of 23 12 2025 Pronouncement: आदेश / O R D E R

For Appellant: NoneFor Respondent: Shri R. R. N. Shukla, Addl. CIT(DR)

Section 143(2)Section 68

income declaring a total income of Rs.54,51,340/- along with agricultural income of Rs.3,50,000/-. Thereafter, the case was selected for limited scrutiny, the reason for such selection being examination of share capital/capital contribution. Accordingly, notice under section 143(2) of the Income

Yash Sugars Limited, Georai vs. PCIT, Nashik-1, Nashik

In the result, the appeal filed by the assessee is dismissed as Infructuous

ITA 1108/PUN/2024[2014-15]Status: DisposedITAT Pune23 Dec 2025AY 2014-15

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1108/Pun/2024 Assessment Year : 2014-15 Yash Sugars Limited, Vs. Pcit, Nashik-1 Plot No.18, Saraswati Colony, Rangar Chowk, Taluk Georai, Georai – 431 127 Maharashtra Pan : Aaacy3092K Appellant Respondent

For Appellant: Shri Shubham RathiFor Respondent: Shri Amit Bobde

Section 143(1)Section 143(2)Section 143(3)Section 263Section 68

para 5 of the impugned order. On legal issue, it is contended by the assessee company that case of the assessee was selected for limited scrutiny under CASS for verification of Amalgamation or Demerger during the year and the Assessing Officer has travelled beyond his jurisdiction and made the addition

M/S. Swabhumi Vintrade Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 7(1), Kolkata

In the result, appeal of the assessee is allowed

ITA 1839/KOL/2025[2017-2018]Status: DisposedITAT Kolkata23 Dec 2025AY 2017-2018

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.1839/Kol/2025 (निर्धारणवर्ा/Assessment Years :2017-2018) M/S Swabhumi Vintrade Pvt. Vs Dcit, Circle-7(1), Kolkata Ltd. 5Th Floor, Hmp House, 4 Fairlie Place, Kolkata, West Bengal-700001 Pan No. :Aancs 9035 P (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्धाररतीकीओरसे /Assessee By : Shri Sunil Surana, Fca रधजस्वकीओरसे /Revenue By : Shri Sandip Sarkar, Jcit, Sr.Dr सुनवाई की तारीख / Date Of Hearing : 09/12/2025 घोषणा की तारीख/Date Of Pronouncement : 23.12.2025 आदेश / O R D E R Per Rajesh Kumar, Am: This Is An Appeal Filed By The Assessee Against The Order Passed By The Ld. National Faceless Appeal Centre (Nfac), Delhi, Dated 28.07.2025For The Assessment Year2017-2018. 2. At The Time Of Hearing, The Assessee Raised Additional Ground Which Is Extracted Below: In This Connection It Is Submitted That The Addition Has Been Made Outside The Issues For Which The Case Was Selected For Limited Scrutiny Which Is Bad In Law & Therefore The Entire Addition Is Liable To Be Deleted. Therefore, The Assessee Is Filing Herewith An Additional Ground Which Goes To The Root Of The Issue & No Fresh Investigation Of Facts Is Required. In View Of The Judgment Of The Hon'Ble Supreme Court In The Case Of Jute Corporation Of India Reported In 187 Itr Page 688 & National Thermal Power Corporation Reported In 229 Itr 383 The Additional Ground May Be Admitted. It Is Requested To Kindly Admit The Additional Grounds Which Are Enclosed Herewith.

For Appellant: Shri Sunil Surana, FCAFor Respondent: Shri Sandip Sarkar, JCIT, Sr.DR

Section 139(1)Section 143(2)Section 68

extracted below: In this connection it is submitted that the addition has been made outside the issues for which the case was selected for limited scrutiny which is bad in law and therefore the entire addition is liable to be deleted. Therefore, the assessee is filing herewith an additional ground ... additional grounds which are enclosed herewith. 2 Additional Ground : “For that the addition made outside the issues for which the case was selected for limited scrutiny is bad in law and therefore the entire addition is liable to be deleted.” 3. After hearing the rival contentions and perusing the material

Sujit Dharamdas Patel, Mumbai vs. ITO Ward 19(3)(1), Mumbai

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

ITA 4939/MUM/2025[2016-17]Status: DisposedITAT Mumbai23 Dec 2025AY 2016-17

Bench: Ms. Kavitha Rajagopal, Jm & Shri Omkareshwar Chidara, Am Mr. Sujit Dharamdas Patel, Acit, Central Circle-2, Ashar It Park, 6Th Floor, 101, First Floor, Patel Chambers, 13 Mathew Road, Wagle Industrial Estate, Shri Rajchandraji Marg, Vs. Thane – 400 604 Opera House, Girgaon, Mumbai – 400 004 Pan:Aafpp5737L (Appellant) : (Respondent)

For Appellant: Shri Dharmesh Shah &For Respondent: Ms. Kavitha Kaushik, Sr. DR

Section 143(1)Section 143(2)Section 143(3)Section 250Section 54F

total income at Rs.16,08,670/- and the same was processed u/s. 143(1) of the Act. The assessee’s case was selected for limited scrutiny under CASS and notices u/s. 143(2) and 142(1) of the Act were duly issued and served upon the assessee. The Learned Assessing

Pankaj Chhatwal, Delhi vs. DCIT Circle-49(1), Delhi

In the result, assessee’s appeal ITA No

ITA 4142/DEL/2025[2018-2019]Status: DisposedITAT Delhi23 Dec 2025AY 2018-2019

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Royassessment Year: 2018-19

Section 142Section 143(3)Section 144BSection 23Section 23(1)(c)Section 250Section 27(1)

assessee, an individual, filed his Income Tax Return on 26.03.2019 declaring income of Rs. 78,08,620/- case whereof was selected for limited scrutiny through CASS for the reasons “The assessee has shown nil ALV despite having shown more than one house property in Schedule-HP of ITR”. Notices were

Bonthula Hari Venkata Krishna, Srikakulam vs. ACIT, Circle-4(1), Visakhapatnam

Appeal is allowed in terms of our aforesaid observations

ITA 581/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam19 Dec 2025AY 2017-18

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.581/Viz/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Bonthula Hari Venkata Vs. The Asst. Commissioner Krishna, Of Income Tax, Visakhapatnam. Circle-4(1), Pan: Agfpb8358K Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 03/12/2025 Hearing: घोषणा की तारीख/Date Of 19/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm :

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 143(3)Section 68

income for AY 2018-19 on 03/10/2017, declaring an income of Rs.1,24,80,020/-. Thereafter, the case of the assessee was selected for “limited scrutiny” under CASS for verifying “large increase in capital in a year”. 4. During the course of the assessment proceedings, the AO observed that

Assistant Commissioner of Income Tax, Circle-1(1), Vijayawada vs. South India Research Institute Private Limited, Vijayawada

ITA 243/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam19 Dec 2025AY 2016-17

Bench: Shri Ravish Sood & Shri Balakrishnan S.

For Appellant: Shri C. Subrahmanyam, CAFor Respondent: Shri Badicala Yadagiri, CIT-DR

Section 143(3)

declaring its total income at Rs. 40,05,510/-. Subsequently, the case of the assessee company was selected for “limited scrutiny” under CASS to examine, viz. (a) mismatch between amounts credited to profit & loss account and other heads of income; and (b) discrepancy between sale consideration reported in the return

Vasavi Club, Hyderabad vs. Income Tax Officer, Ward-11(1), Hyderabad

In the result, the appeal of the assessee is dismissed

ITA 994/HYD/2025[2018-19]Status: DisposedITAT Hyderabad19 Dec 2025AY 2018-19

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 115TSection 142(1)Section 143(1)Section 143(2)Section 144Section 249(2)Section 249(3)

Rs.Nil and accreted income at Rs.19,10,482/- under Section 115TD of the Act. The case was selected for scrutiny through CASS under Limited Scrutiny to verify the issue of taxation of accreted income of trust. Statutory notice under Section 143(2) of the Act, dated 21.09.2019 was issued

Unique Rail Road Consultants Private Limited, Hyderabad vs. DCIT., Central Circle-1(3), Hyderabad

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

ITA 1277/HYD/2025[2015-16]Status: DisposedITAT Hyderabad19 Dec 2025AY 2015-16

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 143(3)Section 250Section 44A

completed the assessment as that of complete scrutiny without following the guidelines of the CBDT, even though the case was, selected for limited scrutiny 4. The Ld. CIT(A) erred in confirming the ad-hoc disallowances without identifying specific bogus expenses. 5. The Ld. CIT(A) ought to have appreciated

Jaydip Dhar, Jalpaiguri vs. ITO, Ward 1(1), Jalpaiguri

Appeal of the assessee is allowed

ITA 642/KOL/2025[2016-17]Status: DisposedITAT Kolkata19 Dec 2025AY 2016-17

Bench: Us That This Appeal Is Time Barred By 421 Days, For Which An Application Has Been Filed By The Assessee For Condoning Of The Said Delay. After Taking Into Account The Reasons Cited By The Ld Ar & Considering The Affidavit On Records We Find That The Delay Is Attributable To The Illness Of The Assessee For Which The Medical Certificate Along With Other Documents Were Placed Before Us

Section 143(2)Section 143(3)Section 250Section 56(2)(vii)Section 69BSection 69C

investment in respect of property u/s 69C of the Act without appreciating the fact that the said issue was not the subject matter of limited scrutiny. 5. The assessee filed return of income on 31.03.2017 declaring total income of Rs. 3,03,720/- which was selected for limited scrutiny through ... challenged the unexplained investments of Rs. 17,81,000/- before the Tribunal on the ground that the said item was not part of the limited scrutiny and therefore, the addition made by the AO is made by exceeding his jurisdiction. The Ld. CIT(A) dismissed the appeal of the assessee

Bishal Jain, Howrah vs. ITO, Ward 47(2), Kolkata

The appeal of the assessee is allowed

ITA 1323/KOL/2025[2016-2017]Status: DisposedITAT Kolkata19 Dec 2025AY 2016-2017

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 250Section 69A

under. 3. The assessee challenged the order of Ld. CIT(A) upholding the assessment order wherein the addition is made beyond the scope of limited scrutiny. 4. The facts in brief are that the assessee filed return of income on 30.03.2017 declaring total income ... which has been reduced to Rs. 4,19,896/-by the Ld. CIT(A). In our opinion, the addition itself beyond the scope of limited scrutiny, therefore, the AO has no jurisdiction to make such addition. Consequently, we direct the AO to delete the addition. The second addition which

Mahendra Shambhulal Thakkar, Ahmedabad vs. ITO, Ward 3(3)(3), Ahmedabad (Existing Ward 3(3)(2), Ahmedabad)

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

ITA 1423/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad18 Dec 2025AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamblemahendra Shambhulal Thakkar, The Income Tax Officer, Vs. B-402, Preet Apt. Ward-3(3)(3), Nr. Sonal Char Rasta, Ahmedabad. Memnagar, (Existing Ward-3(3)(2), Ahmedabad-380052. Ahmedabad.) [Pan :Adlpt4469 N] (Appellant) .. (Respondent) Appellant By : Shri P.D Shah, Ar Respondent By: Shri Prateek Sharma, Sr. Dr Date Of Hearing 18.12.2025 Date Of Pronouncement 18.12.2025

For Appellant: Shri P.D Shah, ARFor Respondent: Shri Prateek Sharma, Sr. DR

Section 143(3)Section 144Section 24BSection 68

passed by the Ld AO is without jurisdiction, against the law and facts, in particular, the Ld.AO has Asst. Year : 2016-17 - 2– converted limited scrutiny assessment into complete scrutiny assessment, without obtaining approval of the Ld. PCIT and therefore the Order passed by Assessing Officer is required ... That your appellant craves a leave to add, alter or amend any grounds at the time of hearing. 3. The case was selected for limited scrutiny in order to examine as to (i) whether sales turnover/receipts has been correctly offered tax and (ii) whether investment and income relating to properties

Singh Construction Corporation, Durgapur vs. DCIT, Central Circle 2, Durgapur

In the result, the appeal of the assessee is allowed

ITA 2182/KOL/2025[2018-2019]Status: DisposedITAT Kolkata18 Dec 2025AY 2018-2019

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: S/shri Manoj Kataruka &For Respondent: Shri S.B. Chakraborthy, DR

Section 143(2)Section 194CSection 69C

Singh Construction Corporation; A.Y. 2018-19 2.1. The facts in brief are that the case of the assessee was selected for limited scrutiny for verification of genuineness of expenses (large payment made u/s 194C) to the persons who had not filed the return of income. Accordingly, notice

Concord Trexim Private Limited, Howrah vs. DCIT, Circle 13(1), Kolkata

Appeal of the assessee is allowed

ITA 2161/KOL/2025[2018-2019]Status: DisposedITAT Kolkata18 Dec 2025AY 2018-2019

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 143(1)Section 143(2)Section 144Section 144BSection 14ASection 250

which is extracted below: “For that the addition made on item which was not the issue for which the case was selected for limited scrutiny is bad in law and the entire addition is liable to be deleted.” 2 Concord Trexim Private Limited 3. The facts in brief are that ... After hearing the rival contention and perusing the material on record, we find that undisputedly, the case of the assessee was selected for limited scrutiny vide notice dated 28.09.2019 issued u/s 143(2) by National E-Assessment Centre (NEAC) for examination of business loss. The assessee has not represented

Jagannath Indrani, Bengaluru, Karnataka vs. Income Tax Officer Ward 4(3)(2), Bangalore

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

ITA 1456/BANG/2025[2017-18]Status: DisposedITAT Bangalore18 Dec 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Mahendra, CAFor Respondent: Shri N. Balusamy, JCIT-DR

Section 142(1)Section 143(2)Section 269SSection 271DSection 69A

case are that the assessee is an individual and filed her return of income on 14/07/2017. Subsequently, the case was selected for limited scrutiny through CASS to examine the cash deposits made during the demonetisation period. Notice u/s. 143(2) was issued on 09/08/2018 and thereafter notices

Chirag Chandrakant Mehta, Mumbai vs. Principal CIT-27, Mumbai

In the result, appeal of the assessee is dismissed

ITA 4397/MUM/2025[2015-16]Status: DisposedITAT Mumbai18 Dec 2025AY 2015-16

Bench: Shri Sandeep Gosain & Shri Girish Agrawalassessment Year: 2015-16 Chirag Chandrakant Mehta Vs Principal Commissioner Of C/O Ca Himanshu Gandhi Income Tax-27, Mumbai 16Th Floor, D Wing, Trade World Building, Kamala Mills Compound, Lower Parel, Mumbai- 400013 Pan: (Aabpm5091L) Appellant Respondent Present For: Appellant By : Shri Himanshu Gandhi, Ca Respondent By : Shri R.A. Dhyani, Cit Dr

For Appellant: Shri Himanshu Gandhi, CAFor Respondent: Shri R.A. Dhyani, CIT DR

Section 133(6)Section 143(2)Section 143(3)Section 144BSection 147Section 263Section 68

have derived Income from Salary, Income from Business and Income from Other Sources. b) My case for AY 2015-16 was selected for LIMITED scrutiny proceeding for verification of issue of "Increase in Capital" vide Notice u/s 143(2) dated 09.08.2016. After detailed verification the assessment was completed