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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Poonam Sodhi, Gurgaon vs. ITO, Gurgaon

In the result, impugned order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 7105/DEL/2025[2017-18]Status: DisposedITAT Delhi15 Dec 2025AY 2017-18

Bench: Shri Vikas Awasthyआअसं.7105/धिल्ली/2025 (नि.व. 2017-18) Poonam Sodhi, 5217, Dlf Phase Iv, Dlf City, Gurgaon, Haryana 122002 ...... अपीलार्थी/Appellant Pan: Bfvps-5961-R बिाम Vs. Income Tax Officer, Hsiidc Building, Vanijya Nikunj, Udhyog Vihar, Phase-V, ..... प्रनिवादी/Respondent Gurgaon, Haryana 122001 अपीलार्थी द्वारा/Appellant By : Shri Saurabh Sharma, Advocate प्रधििािीद्वारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 15/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 15/12/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Additional/Joint Commissioner Of Income Tax (Appeals)-2, Vododara [In Short ‘The Cit(A)’] Dated 04.07.2024, For Assessment Year 2017-18. 2. Shri Saurabh Sharma, Appearing On Behalf Of The Assessee Submits That The Assessee Filed Her Return Of Income For The Assessment Year Under Consideration Declaring Total Income Of Rs. 8,03,000/- Comprising Of Income From House Property & Interest Income. The Case Was Selected For Limited Scrutiny Under Cass To Examine Large Cash Deposits During Demonetization Period Vis-À-Vis The Returned Income. Statutory Notices U/S. 143(2) & 142(1) Of The Income Tax

For Appellant: Shri Saurabh Sharma, AdvocateFor Respondent: Shri Manoj Kumar, Sr. DR
Section 143(2)Section 250Section 250(6)Section 69A

under consideration declaring total income of Rs. 8,03,000/- comprising of income from house property and interest income. The case was selected for limited scrutiny under CASS to examine large cash deposits during demonetization period vis-à-vis the returned income. Statutory notices

Vikas Kumar Dogra, Delhi vs. Assessing Officer Ward 4(5), Gurgaon

In the result, impugned order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 7102/DEL/2025[2017-18]Status: DisposedITAT Delhi15 Dec 2025AY 2017-18

Bench: Shri Vikas Awasthyआअसं.7102/धिल्ली/2025 (नि.व. 2017-18) Vikas Kumar Dogra, Flat No.B-702, Alaknanda Apartment, Gurgaon, Haryana 122011 ...... अपीलार्थी/Appellant Pan: Amypd-3220-D बिाम Vs. Assessing Officer, Ward -4(5), Vanijya Nikunj, Shankar Chowk Road, Phase-V, Udyog Vihar, Sector 19, Gurgaon, ..... प्रनिवादी/Respondent Haryana 122016 अपीलार्थी द्वारा/Appellant By : Shri R. K Gaur, Chartered Accountant प्रधििािीद्वारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 15/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 15/12/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Additional/Joint Commissioner Of Income-Tax (Appeals), Jodhpur (Hereinafter Referred To As ‘The Cit (A)’) Dated 24.09.2025, For The Assessment Year 2017-18. 2. Shri R. K Gaur, Appearing On Behalf Of The Assessee Submits That The Solitary Addition Made By The Assessing Officer (Ao) In The Case Of The Assessee Is On Account Of Credit Card Payment Of Rs.5,36,986/- In Cash During The Period Relevant To Ay 2017-18. The Ld. Counsel Submits That The Ao Had Selected The Case Of Assessee For Limited Scrutiny To Examine The Credit Card Payment In Cash In Respect Of Citi Bank Credit Card No.4386280020862080. The Notice U/S.143(2) Of The Income Tax Act, (Hereinafter Referred To As ‘The Act’) Dated 22.09.2019

For Appellant: Shri R. K Gaur, Chartered AccountantFor Respondent: Shri Manoj Kumar, Sr. DR
Section 143(2)

cash during the period relevant to AY 2017-18. The ld. Counsel submits that the AO had selected the case of assessee for limited scrutiny to examine the credit card payment in cash in respect of Citi Bank credit card no.4386280020862080. The notice u/s.143(2) of the Income

Ankur Dealcom P. Limited, Kolkata vs. ITO, Ward 10(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2204/KOL/2025[2021-2022]Status: DisposedITAT Kolkata11 Dec 2025AY 2021-2022

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.2204/Kol/2025 (निर्धारण वर्ा / Assessment Year : 2021-2022) Ankur Dealcom P. Limited, Vs Ito Ward-10(2), Kolkata C/O S.N.Ghosh & Associates, Advocates, 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kolkata-700001 Pan No. :Aahca 2447 F (अपीलधर्थी /Appellant) (प्रत्यर्थी / Respondent) .. निर्धाररती की ओर से /Assessee By Shri Somnath Ghosh, Ar रधजस्व की ओर से /Revenue By : None सुनवाई की तारीख / Date Of Hearing : 11/12/2025 घोषणा की तारीख/Date Of Pronouncement : 11/12/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 22.07.2025 For The Assessment Year 2021-22. 2. It Was Submitted By The Ld.Ar That The Impugned Assessment Order Would Not Survive, Insofar As In The Order U/S.263 Of The Act Against The Said Assessment Order, The Coordinate Bench Of The Tribunal Has Categorically Held That The Notice U/S.143(2) Of The Act, Dated 20.06.2022 Which Is Culminated In The Assessment Order Dated 23.12.2022, Which Is An Impugned Assessment Order Would Not Survive, Insofar As Notice U/S.143(2) Of The Act Was Not In Conformity With The Cbdt Instruction F.No.225/157/2017/Ita-Ii Dated 23-06-2017. It Was The Submission That As Against The Order U/S.263 Of The Act The Coordinate Bench Of The Tribunal

For Respondent: None
Section 12ESection 143(2)Section 143(3)Section 263

that in terms of the above CBDT instruction, the notice u/s 143(2) has to be in any of the three formats namely; (i) Limited Scrutiny (Computer Aided Scrutiny Selection) (ii) Complete Scrutiny (computer Aided Scrutiny Selection) and (iii) Compulsory Manual Scrutiny. Since, the notice has been issued ... Proceeding' facility for electronic conduct of assessment proceedings in a widespread manner from this financial year. The three formats of notice(s) are: Limited Scrutiny (Computer Aided Scrutiny Selection) Complete Scrutiny (Computer Aided Scrutiny Selection) 4 Compulsory Manual Scrutiny The revised format of 143(2) notice(s) with a note

Yugendar Puppala, Warangal vs. ACIT., Circle-1, Warangal

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

ITA 1329/HYD/2025[2015-16]Status: HeardITAT Hyderabad10 Dec 2025AY 2015-16

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1329/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2015-16) Ms. Yugendra Puppala Vs. Assistant Commissioner Of Warangal Income Tax Pan:Abspp4161E Circle-1, Warangal (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri G. Srinivasa Rao, Ca राज" व "ारा/Revenue By:: Shri Waseem Ur Rehman, Sr.Dr सुनवाई की तारीख/Date Of Hearing: 04/12/2025 घोषणा की तारीख/Pronouncement: 10/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri G. Srinivasa Rao, CAFor Respondent: : Shri Waseem UR Rehman, Sr.DR
Section 142(1)Section 143(2)Section 143(3)Section 144Section 145(3)

holding the impugned assessment order passed by the Assessing Officer as bad-in-law as the AO had extended the scope of the limited scrutiny without obtaining the prior written administrative approval of the concerned Pr. CIT in violation of CBDT Instructions. 2. That on the facts and circumstances ... income of Rs.25,28,380/-. The Page 2 of 6 ITA No 1329 of 2025 Yugendra Puppala case of the assessee was selected for Limited Scrutiny under CASS. Accordingly, notices under section 143(2) and section 142(1) of the Income Tax Act, 1961 (“the Act”) were issued

DCIT, Delhi vs. Mkf Logistics Pvt Ltd, Delhi

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

ITA 3056/DEL/2025[2016-17]Status: DisposedITAT Delhi10 Dec 2025AY 2016-17

Bench: Shri S.Rifaur Rahman & Shri Yogesh Kumar U.S.Dcit, Vs. Mkf Logistics Pvt. Ltd., Delhi. E/63B, South Extension Part 1, New Delhi – 110 049. (Pan : Aaacm5865E) (Appellant) (Respondent) Assessee By : Shri Ajay Wadhwa, Advocate Shri Saksham Garg, Ca Revenue By : Shri Om Prakash, Sr. Dr Date Of Hearing : 18.09.2025 Date Of Order : 10.12.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 04.02.2025 For The Assessment Year 2016-17. 2. Brief Facts Of The Case Are, Assessee Filed Its Return Of Income Declaring Total Income Of Rs.31,32,270/- On 10.09.2016. The Case Was Selected For Limited Scrutiny Under Cass, Accordingly Notices Under Section 143(2)

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 143(2)Section 143(3)Section 194C

case are, assessee filed its return of income declaring total income of Rs.31,32,270/- on 10.09.2016. The case was selected for limited scrutiny under CASS, accordingly notices under section 143(2) 2 and 142(1) of the Income-tax Act, 1961 (for short ‘the Act’) were issued and served ... above mentioned order passed by the AO, the appellant filed the instant appeal. The AO stated that the case was selected under limited scrutiny as receipts u /s 1940 and 194J of the Income tax Act, 1961 (as per 26AS) were more than the receipts shown in ITR 4/5/6 (Service