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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Nitin Gupta, New Delhi vs. ITO Ward - 34(4), New Delhi

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

ITA 9223/DEL/2019[2016-17]Status: DisposedITAT Delhi04 Oct 2021AY 2016-17

Bench: Shri R.K. Pandaassessment Year: 2016-17 Nitin Gupta, Vs. Ito, C-1/23, Ashok Vihar Phase-Ii, Ward-34(4), New Delhi. New Delhi. Pan: Aeapg4313C (Appellant) (Respondent) Assessee By : Shri Rohit Tiwari, Advocate Revenue By : Shri R.K. Gupta, Sr. Dr Date Of Hearing : 26.08.2021 Date Of Pronouncement : 04.10.2021 Order

For Appellant: Shri Rohit Tiwari, AdvocateFor Respondent: Shri R.K. Gupta, Sr. DR
Section 5Section 95

consultancy. He filed his return of income on 29th March, 2017 declaring total income at Rs.4,89,280/-. The case was selected for limited scrutiny through CASS for examination whether investment and income relating to foreign immovable property are duly disclosed. During the course of assessment proceedings, the AO noted

V.V.Trust, New Delhi vs. ITO, Exemption, Ward-2(3), New Delhi

Appeal of the assessee is allowed

ITA 3687/DEL/2018[2014-15]Status: DisposedITAT Delhi27 Aug 2021AY 2014-15

Bench: Shri Kul Bharata N D Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Suresh Gupta, C. AFor Respondent: Shri Govind Singhal, Sr. DR
Section 143(3)Section 271(1)(C)Section 271(1)(c)

should be levied. Several case laws were also cited before him. The Assessing Officer noted that the return of the assessee was selected for limited scrutiny only to examine substantial increase in the rental income of the assessee and, therefore, revised return was after detection and he held that assessee

Amit Saini, New Delhi vs. ACIT, Circle-28(1), New Delhi

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

ITA 9335/DEL/2019[2016-17]Status: DisposedITAT Delhi26 Aug 2021AY 2016-17

Bench: Shri R.K. Pandaassessment Year: 2016-17 Amit Saini, Vs. Acit, A-178/10, 3Rd Floor, Circle-28(1), Dayanand Colony, New Delhi. Lajpat Nagar-4, New Delhi. Pan: Azmps6422R (Appellant) (Respondent) Assessee By : Shri Satyendra Kumar Chaturvedi, Ca Revenue By : Shri R.K. Gupta, Sr.Dr Date Of Hearing : 26.08.2021 Date Of Pronouncement : 26.08.2021 Order

For Appellant: Shri Satyendra Kumar Chaturvedi, CAFor Respondent: Shri R.K. Gupta, Sr.DR
Section 68

return of income on 2nd August, 2017 declaring the total income at Rs.2,63,600/-. The case of the assessee was selected for limited scrutiny through CASS on the ground that the assessee has shown large agricultural income. During the course of assessment proceedings, the AO noted that the assessee

York Tech Pvt. Ltd., New Delhi vs. DCIT Circle-25(1), New Delhi

The appeal of the assessee is allowed

ITA 635/DEL/2021[2016-17]Status: DisposedITAT Delhi18 Aug 2021AY 2016-17

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

For Appellant: Shri Ajay Wadhwa, Adv. and MsFor Respondent: Ms. Meera Srivastava, CIT-DR and Shri M. Baranwal, Sr.D.R
Section 143(2)Section 143(3)Section 144C(5)Section 92B

slump sale price.” 3. The return of income was filed on 03.09.2016 declaring income of Rs.3,77,140/-. The said return was selected for limited scrutiny assessment under the E-assessment Scheme, 2019. Accordingly, notice u/s. 143(2) was issued on 21.07.2017. The ld. Assessing Officer noted that assessee

Shalini Securities Pvt Ltd, New Delhi vs. ITO Ward 23(1), New Delhi

Appeal of the assessee is allowed

ITA 3001/DEL/2019[2015-16]Status: DisposedITAT Delhi12 Aug 2021AY 2015-16

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: N o n eFor Respondent: Shri R. K. Gupta, Sr. D. R
Section 143(3)Section 40ASection 40A(2)(b)

facts in sustaining the addition of Rs.5,04,000.00 ignoring the fact that the this is beyond the scope of ground of limited scrutiny. Hence, the addition, as such, may be deleted. 3. That the honorable CIT (A)-XXV has erred in law and on facts in sustaining the addition ... revised on 31.10.2015 at Rs. 8,65,150/-. The case of the assessee was selected for scrutiny through CASS for limited scrutiny. 7. During the course of assessment proceedings the ld AO noted that the assessee has paid salary of Rs. 1,26,000/- each to four lady employees

Sri Ganraj Buildcon Private Limited, New Delhi vs. ACIT (OSD) Ward - 24(2), New Delhi

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

ITA 1760/DEL/2020[2016-17]Status: DisposedITAT Delhi04 Aug 2021AY 2016-17

Bench: Shri R.K. Pandaassessment Year: 2016-17 Sri Ganraj Buildcon Private Ltd., Vs. Acit (Osd), H-255, Phase-I, Ward-24(2), Ashok Vihar, New Delhi. New Delhi. Pan: Aavcs3068C (Appellant) (Respondent) Assessee By : None Revenue By : Shri R.K. Gupta, Sr.Dr Date Of Hearing : 04.08.2021 Date Of Pronouncement : 04.08.2021 Order This Appeal By The Assessee Is Directed Against The Ex Parte Order Dated 18Th February, 2020 Of The Cit(A)-8, New Delhi, Relating To Assessment Year 2016-17. 2. Notice Issued Through Registry Was Returned Unserved By The Postal Authorities With The Remark “Left Without Address.” Therefore, This Appeal Is Being Decided On The Basis Of Material Available On Record & After Hearing The Ld. Dr. 3. Although A Number Of Grounds Of Appeal Have Been Raised By The Assessee, These All Relate To The Ex Parte Order Of The Cit(A) In Confirming The Addition Of Rs.26,22,300/- Made By The Ao In The Order Passed U/S 143(3) Of The It Act, 1961. 4. Facts Of The Case, In Brief, Are That The Assessee Is A Private Limited Company & Is Engaged In The Business Of Real-Estate Developers, Builders, Engineers, Surveyors, Contractors, Etc. It Filed Its Return Of Income On 28Th March, 2017 Declaring The Total Income At Rs.32,840/-. The Case Of Assessee Was Selected For Limited Scrutiny Under Cass For The Following Reasons:- “(I) “High Cash In Hand Shown In Balance Sheet As Compared To Preceding Year & Return Of Income Filed After 07.11.2016. Whether Cash In Hand Shown In Return Of Income Is Correct” & (Ii) “Large Investment In Property As Compared To Total Income & Whether Investment & Income Relating To Properties Are Duly Disclosed".

For Appellant: NoneFor Respondent: Shri R.K. Gupta, Sr.DR
Section 142(1)Section 143(3)Section 68

filed its return of income on 28th March, 2017 declaring the total income at Rs.32,840/-. The case of assessee was selected for limited scrutiny under CASS for the following reasons:- “(i) “High Cash in hand shown in balance sheet as compared to preceding year and return of income filed

Muon Computing P.Ltd, New Delhi vs. ITO, Ward-17(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 7606/DEL/2019[2016-17]Status: DisposedITAT Delhi04 Aug 2021AY 2016-17

Bench: Shri Kul Bharatassessment Year : 2016-17 Muon Computing P.Ltd., Vs Ito, G-28/119-120, 2Nd Floor, Ward-17(2), Sector-3, Rohini, New Delhi. New Delhi-110085. Pan-Aahcm6193J Appellant Respondent Appellant By Sh.K.Sampath, Adv. & Sh. V.Raj Kumar, Adv. Respondent By Sh.Gaurav Pundir, Sr. Dr Date Of Hearing 20.07.2021 Date Of Pronouncement 04.08.2021

case was selected for scrutiny through CASS. It is recorded by the Assessing Assessment Year : 2016-17 Officer that the case was selected for limited scrutiny. The reason for selecting case for limited scrutiny is stated in the assessment order that there was high cash on hand disclosed

Deepshikha Negi, New Delhi vs. ITO Ward - 43(5), New Delhi

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

ITA 6581/DEL/2019[2016-17]Status: DisposedITAT Delhi04 Aug 2021AY 2016-17

Bench: Shri R.K. Pandaassessment Year: 2016-17 Deepshikha Negi, Vs. Ito, 103, Dda Flats, Ward-43(5), Dwarka Sec.2, New Delhi. Pocket-1, New Delhi. Pan: Afmpn4074Q (Appellant) (Respondent) Assessee By : Shri S.K. Goyal, Ca Revenue By : Shri R.K. Gupta, Sr.Dr Date Of Hearing : 04.08.2021 Date Of Pronouncement : 04.08.2021 Order This Appeal By The Assessee Is Directed Against The Order Dated 17Th June, 2019 Of The Cit(A)-15, New Delhi, Relating To Assessment Year 2016-17. 2. The Assessee In Her Grounds Of Appeal Has Challenged The Order Of The Cit(A) In Confirming The Disallowance Of Rs.4,56,707/- On Account Of Derivative Trnsaction.

For Appellant: Shri S.K. Goyal, CAFor Respondent: Shri R.K. Gupta, Sr.DR
Section 142(1)Section 143(2)Section 144Section 2

individual and filed her return of income on 30th July, 2016 declaring the total income at Rs.2,63,170/-. The case was selected for limited scrutiny under CASS to verify whether the investment and income relating to securities (derivative transactions) are duly disclosed. Subsequently, notice u/s 143(2) was issued

Shivam Securities P.Ltd, New Delhi vs. DCIT, Circle-23(2), New Delhi

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

ITA 554/DEL/2019[2014-15]Status: DisposedITAT Delhi14 Jul 2021AY 2014-15

Bench: Shri P. M .Jagtap, Vice-(Kz) & Shri A. T. Varkey, Jm]

Section 131Section 133(6)Section 68

received share capital and premium to the tune of Rs. 25,54,50,000/- in this relevant assessment year. And, therefore, as per the limited scrutiny i.e. purpose of selection “Introduction of Capital & Receipt of large share premium”, the AO asked the assessee to prove the identity, creditworthiness and genuineness

Sunila Awasthi, New Delhi vs. Pr.CIT-12, New Delhi

In the result, appeal filed by the assessee is allowed

ITA 496/DEL/2021[2015-16]Status: DisposedITAT Delhi07 Jul 2021AY 2015-16

Bench: Ms. Suchitra Kamblea N D Shri Prashant Maharishii.T.A. No. 496/Del/2021 (A.Y. 2015-16) (Through Video Conferencing) Ms. Sunila Awasthi, Principal Cit – 12, E–802, Uniworld City East, Vs. New Delhi. Sector : 30, Gurugram, Haryana. Pan : Aaepa9591J (Respondent) (Appellant) Assessee By : Shri Deepak Chopra, Adv.; & Shri Harpreet Singh Ajmani, Advocate; Department By : Shri H. K. Chaudhary [Cit] – Dr; Date Of Hearing 01.07.2021 Date Of Pronouncement 07.07.2021

For Appellant: Shri Deepak Chopra, Adv.; &For Respondent: Shri H. K. Chaudhary
Section 139(5)Section 143(2)Section 143(3)Section 263Section 271(1)Section 271(1)(c)

return was revised on 31st December 2016 declaring total income of Rs. 1,97,54,000/-. The case of the assessee was selected for limited scrutiny through computer added selection system and the reasons were: (i) Contract receipt / fees mis-match; (ii) Sales turnover mis-match; and (iii) Tax credit

Ad 2C (India) Pvt Ltd, Gurgaon vs. ACIT Circle-1(1), Gurgaon

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

ITA 999/DEL/2019[2015-16]Status: DisposedITAT Delhi30 Jun 2021AY 2015-16

Bench: Shri Kul Bharatassessment Year : 2015-16 Ad 2C (India) Pvt.Ltd., Vs Acit, 601- 612, 6Th Floor, Jmd Circle-1(1), Megapolis, Sector-48, Sohna Gurgaon. Road, Gurgaon-122018. Pan-Aajca7779A Appellant Respondent Appellant By Sh. S. Krishna, Adv. Respondent By Sh. R. K.Gupta, Sr.Dr Date Of Hearing 23.06.2021 Date Of Pronouncement 30.06.2021

Written Off Rs.294025.” 2. Facts giving rise to the present appeal are that case of the assessee was picked up for scrutiny assessment for limited scrutiny under CASS. The Assessing Officer while framing the assessment, called upon the assessee to explain regarding provision of doubtful receivables of Rs.11

Rajani Venkata Naga Anavarapu Narayna, New Delhi vs. Pr.CIT-20, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1817/DEL/2020[2015-16]Status: DisposedITAT Delhi16 Jun 2021AY 2015-16

Bench: Ms. Suchitra Kambledr. B. R. R. Kumarita No. 1817/Del/2020 : Asstt. Year: 2015-16 Rajani Venkata Naga Annavarapu Vs Pcit-20, Narayana, A-14, Mangal Co-Operative New Delhi Group Housing Society Ltd., Vasundhara Enclave, Delhi-110096 (Appellantt (Respondent) Pan No. Agbpn4766D

For Appellant: Sh. Manoj Kumar, CAFor Respondent: Ms. Pramita M. Biswas, CIT DR
Section 143(3)Section 263Section 48Section 54Section 68

income for the year under consideration was filed on 21.08.2015 declaring income of Rs.67,050/-. The case of the appellant was selected for limited scrutiny. The issues of limited scrutiny were:- I) Cash deposit II) Purchase of property 5. The ld. PCIT issued notice dated ... this notice is reproduced as under for ready reference: 3 Rajani Venkata Naga Anavarapu Narayna “2. Your case had been selected for “Limited Scrutiny” under CASS on the following reasons: 1. Large cash deposited in saving bank account. 2. Purchase of property. The assessment was completed

Rohit Dhupar, New Delhi vs. ITO Ward - 28(1), New Delhi

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

ITA 9684/DEL/2019[2016-17]Status: DisposedITAT Delhi14 Jun 2021AY 2016-17

Bench: Shri Kul Bharatassessment Year : 2016-17 Rohit Dhupar, Vs Ito, D-942, New Friends Colony, Ward-28(1) New Delhi-110065. New Delhi. Pan-Aafpd5114P Appellant Respondent Appellant By Sh. Amit Kaushik, Advocate Respondent By Sh. R.K.Gupta, Sr.Dr Date Of Hearing 25.05.2021 Date Of Pronouncement 14.06.2021

Section 234BSection 271(1)

assessee e-filed return of income for the year under appeal on 20.09.2016 declaring income of Rs.8,28,250/-. The case was selected for limited scrutiny. Accordingly, statutory notice was issued and served upon the assessee. During the course of assessment, the Assessing Officer observed that the assessee had shown

Avtar Singh Dheeran, Delhi vs. ITO, Ward- 66(5), New Delhi

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

ITA 403/DEL/2018[2014-15]Status: DisposedITAT Delhi10 Jun 2021AY 2014-15

Bench: Shri R.K. Pandaassessment Year: 2014-15 Avtar Singh Dheeran, Vs Ito, C/O Kapil Goel, Advocate, Ward-66(5), G-26/124, Sector-7, New Delhi. Rohini, New Delhi. Pan: Aaipd8887G (Appellant) (Respondent) Assessee By : Shri Kapil Goel, Advocate Revenue By : Shri Rajesh Kumar, Sr. Dr Date Of Hearing : 20.04.2021 Date Of Pronouncement : 10.06.2021 Order

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Shri Rajesh Kumar, Sr. DR

return of income on 14th October, 2014 declaring the total income of Rs.1,31,638/-. The case of the assessee was selected for limited scrutiny with the reason ‘long-term capital loss on sale of property.’ During the course of assessment proceedings, the AO noted that the assessee has sold

Manoj Singhal, New Delhi vs. Pr. CIT-5, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1731/DEL/2020[2015-16]Status: DisposedITAT Delhi28 May 2021AY 2015-16

Bench: Sh. Bhavnesh Sainidr. B. R. R. Kumarita No. 1731/Del/2020: Asstt. Year: 2015-16 Manoj Singhal, Vs Pr. Cit-5, H. No. 9-10, Alipur Road, Civil Lines, New Delhi New Delhi-110032 (Appellantt (Respondent) Pan No. Aozps8161B

For Appellant: Sh. Amit Goel, AdvFor Respondent: Ms. Pramita Biswas, CIT DR
Section 143(3)Section 2Section 263Section 54F

income for the year consideration was filed on 27.09.2015 declaring income of (-Rs.3,30,61,960/-). The case of the appellant was selected for limited scrutiny. The issues of limited scrutiny were:- I) Purchase of property II) Deduction claimed under the head-capital gain 5. The ld. PCIT issued notice ... arguments of both the parties. 7. The primary contention of the ld. AR is that the case of the assessee has been selected for limited scrutiny on two grounds viz. verification of Purchase of property and verification of deduction claimed under the head capital gain and expanding the scope

Shri Krishna Mohan Chuorsiya, Rajgarh vs. The Pr. CIT Ujjain, Ujjain

ITA 626/IND/2019[2014-15]Status: DisposedITAT Indore25 May 2021AY 2014-15

Bench: Shri Manish Borad & Mis Madhumita Royassessment Year:2014-15 Shri Krishna Mohan Pr. Cit Choursiya(Prop. Of M/S Laxmi Ujjain Mp बनाम/ Auto Parts) Vs. Ward No.14, Bus Stand, Kurawar Rajgarh(M.P.) (Appellant) (Respondent ) P.A. No.Aempc3634G

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

return of income for A.Y. 2014- 15 on 28.11.2014 declaring total income of Rs.3,83,280/-. The case of the appellant was selected for limited scrutiny through CASS and notice dated 31-08-2015 under section 143(2) was issued for the assessment year 2014-15 and duly served upon

Crown International, Delhi vs. ACIT, Circle- 41(1), New Delhi

In the result, appeal of the assessee is allowed

ITA 2531/DEL/2019[2014-15]Status: DisposedITAT Delhi18 May 2021AY 2014-15

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri V K Shabarwal Adv alongwith Shri Ashok BabbarFor Respondent: Shri Mahesh Thakur SR DR

profession. Assessee has filed its return of income declaring income of ₹ 71,531,420/– on 31/11/2014. The case of the assessee was selected for limited scrutiny to examine mismatch in profit before tax as per profit and loss account and schedule BP, high interest expenditure against capital shown

Shri Shaligram Barod, Indore vs. Pr. CIT-1, Indore

ITA 625/IND/2019[2014-15]Status: DisposedITAT Indore30 Apr 2021AY 2014-15

Bench: Hon'Ble Manish Borad & Hon'Ble’ Madhumita Royassessment Year:2014-15 Shri Shaligram Barod, Pr. Cit-I, Ah/29, Hig, Sukhliya Indore बनाम/ Indore Vs. (Appellant) (Respondent ) P.A. No. Ahfpp4068H Appellant By Shri S.N. Agrawal, Ca Revenue By Shri S.B. Prasad, Cit-Dr

Section 143(3)Section 263Section 40A(2)(b)Section 54Section 54BSection 54FSection 54F(1)

Income from Long Term Capital Gain 1,93,656 3. The case of the assessee was selected for limited scrutiny for following terms: S.No Reason for selection of case in scrutiny 1 Large deduction claimed u/s 54B,54C,54D, 54G, 54GA 2 Sale consideration of the Property ... portion of the show cause notice issued u/s 263 of the Act is reproduced as under- 4.1·Two main issues to be examined under limited scrutiny were difference in consideration property sold and large deduction claimed against capital gain income. On perusal 0/ assessment records it is 4 Shaligram Borad

Virendra Pratap, Delhi vs. ITO, Ward- 61(3), New Delhi

ITA 3486/DEL/2018[2014-15]Status: DisposedITAT Delhi23 Apr 2021AY 2014-15

Bench: Shri N.K. Billaiya & Shri Kuldip Singh

For Appellant: Shri Ved Jain, CAFor Respondent: Ms. Ranu Mukharji, Senior DR
Section 133Section 40Section 44A

learned AO has erred both on facts and in law in extending the scope of assessment, inspite of the same having been selected for limited scrutiny. 3. On the facts and circumstances of the case, the learned AO has erred both on facts and in law in making assessment

Amit Kumar Dey, Delhi vs. DCIT, Circle-1(1), Gurgaon

In the result, appeal of the assessee is allowed

ITA 5526/DEL/2018[2015-16]Status: DisposedITAT Delhi30 Mar 2021AY 2015-16

Bench: Shri Amit Shuklaa N D Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Kapil Goel, AdvFor Respondent: Shri Ajay Kumar, Sr. DR
Section 143(2)Section 143(3)Section 54

notice of enhancement, secondly on extant facts said enhancement could not have been done as per dear proscription under the statute and thirdly only limited scrutiny proceedings was going on before Ld AO as per notice u/s 143(2) dated 20/09/2016 on issue of“deduction claimed under the head capital ... income from other sources. He filed return of income on 31.08.2015 for Rs.1,28,09,820/-. The case of the assessee was selected for limited scrutiny as per notice dated 20th September 2016 for examination of deduction claimed under the head capital gains. During the year assessee has claimed deduction