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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Srinivasa Rao Palabhatla, Hyderabad vs. ITO., Ward-7(1), Hyderabad

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

ITA 293/HYD/2025[2017-18]Status: HeardITAT Hyderabad14 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.293/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Srinivasa Rao Vs. Income Tax Officer Palabhatla, Hyderabad Ward – 7 (1) Pan:Aiupp8507H Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate S. Sandhya राज" व "ारा/Revenue By:: Shri R. Kumaran, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 11/11/2025 घोषणा की तारीख/Pronouncement: 14/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Srinivasa Rao Palabhatla, (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, (Nfac), Delhi (“Ld. Cit(A)”) Dated 04.05.2023 For The A.Y 2017-18. 2. At The Outset, It Is Seen That There Is A Delay Of 571 Days In Filing The Appeal Before This Tribunal. The Assessee Has Filed A Condonation Petition & Affidavit Along With Copies Of Page 1 Of 6

For Appellant: Advocate S. SandhyaFor Respondent: : Shri R. Kumaran, Sr. DR

income for the Assessment Year 2017-18 on 30.03.2018, declaring total income of Rs.7,93,660/-. The case of the assessee was selected for limited scrutiny under CASS and accordingly notices under section 143(2) and section 142(1) of the Income Tax Act, 1961 (“the Act”) were issued

Abuchi Infra Ventures Limited, Delhi vs. Income Tax Officer, Ward-2(3), Delhi

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

ITA 2712/DEL/2023[2017-18]Status: DisposedITAT Delhi14 Nov 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmaabuchi Infra Ventures Limited, Vs. Ito, Ward 2 (3), Kh No.115, Village Alipur, Delhi. Delhi – 110 036. (Pan : Aacb5801K) (Appellant) (Respondent) Assessee By : Shri Harshit Srivastav, Ca Revenue By : Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing : 29.10.2025 Date Of Order : 14.11.2025 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 01.08.2023For The Assessment Year 2017-18. 2. Brief Facts Of The Case Are, Assessee Filed Its Return Of Income For Ay 2017-18 On 07.11.2017 Declaring An Income Of Rs.1,27,520/-. The Case Was Selected For Limited Scrutiny Under Cass & Accordingly, Notices U/S 143(2) & 142(1) Of The Income-Tax Act, 1961 (For Short ‘The Act’)

For Appellant: Shri Harshit Srivastav, CAFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 115BSection 142(1)Section 143(2)Section 69

assessee filed its return of income for AY 2017-18 on 07.11.2017 declaring an income of Rs.1,27,520/-. The case was selected for limited scrutiny under CASS and accordingly, notices u/s 143(2) and 142(1) of the Income-tax Act, 1961 (for short ‘the Act’) 2 along with ... along with registered deed in his order. After considering the above facts on record ld. CIT (A) observed that the case was selected for limited scrutiny under CASS for the purpose of verifying the following issues :- (i) Expenses incurred for earning exempt income; (ii) Investment/Advances/Loans; and (iii) Investment in immovable