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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

M/S. Assam Industrial Development Corporation Ltd., Guwahati vs. Deputy Commissioner of Income-Tax, Circle-3, Guwahati

In the result, the appeal of the assessee is allowed

ITA 97/GTY/2020[2017-18]Status: HeardITAT Guwahati20 Nov 2025AY 2017-18

Bench: Shri Rajesh Kumar & Shri Manmohan Dasassessment Year: 2017-18 Assam Industrial Development Corporation Ltd……................……….……Appellant A-4, R G Baruah Road, Ambikagiri Nagar, Guwahati, Assam-781024. [Pan: Aacca4720A] Vs. Acit, Circle-3, Guwahati.………..…………………………...……...…..…..Respondent Appearances By: Shri Somnath Ghosh, Advocate & Amalan Bhadra, Fca, Appeared On Behalf Of The Appellant. Shri Sanjay Jha, Cit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 18, 2025 Date Of Pronouncing The Order : November 20, 2025 Order Per Rajesh Kumar: This Is An Appeal Preferred By The Assessee Against The Order Of The Cit(Appeals)-2, Guwahati (Hereinafter Referred To As The “Ld. Cit(A)”] Dated 27.02.2020 For The Ay 2017-18. 2. At The Outset, During The Course Of Assessment Proceedings, The Assessee Has Raised Legal Issue Challenged The Assessment Framed Based On Notice Issued U/S 143(2) Of The Act Which Is Not In Accordance With Instruction No. F. No. 225/157/2017/Ita-Ii Dated 23- 06-2017, Issued By The Cbdt.

Section 143(2)Section 143(3)

vehemently submitted that the notice u/s 143(2) of the Act does not specify whether it is a limited scrutiny or a complete scrutiny or a compulsory manual scrutiny. The ld. AR submitted that the CBDT has issued specific instruction vide instruction no. F. No. 225/157/2017/ITA-II Dated

Prem Grain Industries Pvt. Ltd, Jalgoan vs. DCIT Circle 1, Jalgaon

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

ITA 2012/PUN/2025[2016-17]Status: PendingITAT Pune20 Nov 2025AY 2016-17

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17 Prem Grain Industries Pvt. Ltd. Dcit, Circle – 1, Jalgaon E 2/1, Midc Area, Ahjantha Vs. Road, Jalgaon – 425003 Pan: Aadcp9598E (Appellant) (Respondent) Assessee By : Shri Suresh Anchaliya Department By : Shri S. Sadananda Singh, Jcit Date Of Hearing : 11-11-2025 Date Of Pronouncement : 20-11-2025 O R D E R Per R.K. Panda, Vp: This Appeal Filed By The Assessee Is Directed Against The Order Dated 22.07.2025 Of The Ld. Cit(A), Pune-12 Relating To Assessment Year 2016-17. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Company & Filed Its Return Of Income On 01.09.2016 Declaring Total Income Of Rs.Nil. The Return Was Processed U/S 143(1) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). The Case Was Selected For Limited Scrutiny Through Cass For The Following Issue: “Whether Unsecured Loans Are Genuine & From Disclosed Sources.”

For Appellant: Shri Suresh AnchaliyaFor Respondent: Shri S. Sadananda Singh, JCIT
Section 131Section 132Section 132(4)Section 133(6)Section 143(1)Section 143(2)Section 144Section 68

return was processed u/s 143(1) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’). The case was selected for limited scrutiny through CASS for the following issue: “Whether unsecured loans are genuine and from disclosed sources.” 3. Accordingly statutory notices

Gmedapadu Pacs, East Godavari vs. ITO, Ward-1, Kakinada

ITA 573/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam19 Nov 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.573/Viz/2025 (निर्धारण वर्ा/Assessment Year:2018-19) Gmedapadu Pacs, Vs. Income Tax Officer, East Godavari District, Ward-1, Andhra Pradesh. Kakinada. Pan: Aaaag8455A (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri Kss Sarma, Ca रधजस् व द्वधरध/Revenue By: Dr. Aparna Villuri, Sr. Ar सुिवधई की तधरीख/Date Of Hearing: 16/10/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Society Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 18/08/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 10/02/2021 For Ay 2018-19. The Assessee Society Has Assailed The Impugned Order Passed By The Ao On The Following Grounds Of Appeal:

For Appellant: Sri KSS Sarma, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(3)Section 80P

claiming deduction under section 80P of the Act of Rs. 84,01,394/-). 3. Thereafter, the case of the assessee society was selected for “limited scrutiny” for verifying its claim for deduction from total income under Chapter VI-A. 4. The AO, vide his order passed under section ... view of material available on record, no addition on the subject issue for which the case of the assessee society was selected for “limited scrutiny” was being made, but the at the same time observed that the assessment of income was being done as per the “computation sheet

Jayashree Sanjay Jadhav, Mumbai City vs. Assistant Commissioner of Income Tax, Circle 42 (2) (3), Mumbai

In the result, the Assessee’s appeal is allowed in the said terms

ITA 5660/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Nov 2025AY 2017-18

Bench: Shri Narender Kumar Choudhryassessment Year: 2017-18 Ms. Jayashree Sanjay Acit, Circle 42(2)(3), Jadhav, Kautalya Bhavan, Bandra H 11/703, Palm Acres Chs Ltd. Vs. Kurla Complex, Pratiksha Nagar, Sion, Bandra (East), Mumbai – 400022. Mumbai - 400051 Pan: Adgpj9973J (Appellant) (Respondent) Present For: Assessee By : Shri Anant Pai, Ld. A.R. Revenue By : Shri Vikas Chandra, Ld. Sr. D.R. Date Of Hearing : 17.11.2025 Date Of Pronouncement : 17.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 31.07.2025, Impugned Herein, Passed By Ld. Commissioner Of Income Tax (Appeals) Addl/Jcit (A) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2008-09. 2. Admittedly, The Case Of The Assessee Was Selected For Scrutiny For The Following Issues: (I) Cash Deposit In The Bank Account During Demonetization Period From 09.11.2016 To 31.12.2016. (Ii) Transactions Made In Immovable Property & (Iii) Investment Of Rs.1,50,000/- U/S 80C.

For Appellant: Shri Anant Pai, Ld. A.RFor Respondent: Shri Vikas Chandra, Ld. Sr. D.R
Section 143(3)Section 250Section 69ASection 80C

authorities below were empowered to examine the cash deposits made during the period from 09.11.2016 to 31.12.2016 only, as the case was selected for limited scrutiny of the issues mentioned above and was not converted complete scrutiny. However, the AO still made the addition of Rs.15,04,500/- by considering