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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Apex Irrigation, Rajkot vs. Commissioner of Income Tax Appeals, National Faceless Assessment Centre, Delhi

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

ITA 94/RJT/2025[2017-2018]Status: DisposedITAT Rajkot30 Oct 2025AY 2017-2018

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri Brijesh Parekh, Ld. A.RFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 253(5)Section 40Section 5Section 68

Assessment Year 2017-18 was e-filed by assessee on 30/10/2017 declare Income at Rs. 5,51,700/-. The case was selected for limited scrutiny in CASS for e- assessment proceedings, a statutory notice u/s. 143(2) of the I.T Act, 1961 was issued on 12/08/2018 which was served

Tom George, Palakkad vs. The Income Tax Officer, Ward-1 & Tps, Palakkad

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

ITA 492/COCH/2025[2018-19]Status: DisposedITAT Cochin30 Oct 2025AY 2018-19

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.Assessment Year : 2018-19

For Respondent: Shri. Padmanathan K V

Section 143(2)Section 28

firm of M/s. Kizhakkeparambil Natural Rock Constructions LLP and filed his return of income on 06/09/2019. Subsequently, the case was selected for limited scrutiny under CASS and notices u/s. 143(2) and 142(1) were issued. The assessee had received a remuneration of Rs. 39,99,577/- from the firm

Mohammed Husain, Indore vs. Income-Tax Officer, 4(1), Indore

Appeal is allowed for statistical purpose

ITA 761/IND/2024[2017-18]Status: DisposedITAT Indore30 Oct 2025AY 2017-18

Bench: Shri B.M. Biyani

Section 143(2)Section 143(3)Section 144Section 69A

761/Ind/2024 - AY 2017-18 2. Ld. AR for assessee draws us to assessment-order and submits that the assessee’s case was selected for limited scrutiny with the reason that large cash deposits in bank a/cs were made by assessee during the previous year 2016-17 relevant

Shri Jitendra Behl, Sriganganagar vs. ITO, Ward-3(2), Jaipur

In the result, the appeal of the assessee is allowed

ITA 1080/JPR/2024[2017-18]Status: DisposedITAT Jaipur30 Oct 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Mrs. Raksha Birla, C.AFor Respondent: Shri Gautam Singh Choudhary, JCIT a

Section 143(3)Section 250Section 69A

income on e-filing portal for the A.Y. 2017-18 on 29.03.2018 declaring total income at Rs.2,92,300/-. The case was selected for Limited SCRUTINY assessment under CASS. Notice u/s 143(2) was issued on 09.08.2018 by the ld. AO. Further notice

Shri Babu Lal, Lucknow vs. DCIT, Range-6, Lucknow

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

ITA 203/LKW/2020[2015-16]Status: DisposedITAT Lucknow30 Oct 2025AY 2015-16

Bench: Shri Kul Bharat & Shri Nikhil Choudharyआयकर अपील सं/ Ita No.203/Lkw/2020 ननिाारण वर्ा/ Assessment Year: 2015-16 Babu Lal V. Dcit, Range-6 205, Amar Shaheed Path, 3Rd Floor, P. K. Complex, Aurangabad Jagir, Lucknow- 27/2, Raja Ram Mohan 226009. Marg, Lucknow-226001. Pan:Afdpl7463G 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: 27 10 2025 घोर्णा कक तारीख/ Date Of 30 10 2025 Pronouncement: आदेश / O R D E R

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

Section 143(2)Section 250Section 68

this case, the assessee filed his return of income on 28.09.2015, declaring total income at Rs.18,83,080/-. Thereafter, the case was selected for limited scrutiny through Computer Assisted Scrutiny System (CASS). Accordingly, a notice u/s 143(2) of the Act was issued and served upon the assessee. In response

Kapil Chamanlal Setia, Dhule vs. Addl/Joint/Dy/Asst.CIT/ITO, Itd, National Faceless Assessment Centre, Delhi

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

ITA 810/PUN/2025[2018-19]Status: DisposedITAT Pune30 Oct 2025AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.810/Pun/2025 Assessment Year : 2018-19

For Appellant: Shri Sharad ShahFor Respondent: Shri Ramnath P Murkunde

Section 143(3)Section 250

individual and declared income of Rs.2,49,858/- in the return of income for A.Y. 2018-19 filed on 02.03.2019. Case selected for Limited Scrutiny on the issue of Cash Withdrawals and Sales Turnover/Receipts. As per the information from Insight portal, ld. Assessing Officer (AO) observed that the assessee

Deepak Sarda, Pune, Maharashtra vs. Income Tax Officer, Ward - 3(2), Pune, Maharashtra

ITA 1580/PUN/2025[2014-15]Status: DisposedITAT Pune30 Oct 2025AY 2014-15

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Adv. Simran Dhawan (virtually)For Respondent: Shri Deepak Kumar Kedia, JCIT

Section 133(6)Section 142(1)Section 143(2)Section 271(1)(c)Section 271BSection 44A

assessee is an individual and filed his return of income on 29.07.2015 declaring total income of Rs.2,85,200/-. The case was selected for limited scrutiny under CASS on account of the following reasons: a) Large investment in property as compared to total income b) Low capital gain with respect

Deepak Sarda, Pune, Maharashtra vs. Income Tax Officer, Ward - 3(2), Pune, Maharashtra

ITA 1579/PUN/2025[2014-15]Status: DisposedITAT Pune30 Oct 2025AY 2014-15

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Adv. Simran Dhawan (virtually)For Respondent: Shri Deepak Kumar Kedia, JCIT

Section 133(6)Section 142(1)Section 143(2)Section 271(1)(c)Section 271BSection 44A

Deepak Sarda, Pune, Maharashtra vs. Income Tax Officer, Ward - 3(2), Pune, Maharashtra

ITA 1578/PUN/2025[2014-15]Status: DisposedITAT Pune30 Oct 2025AY 2014-15

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Adv. Simran Dhawan (virtually)For Respondent: Shri Deepak Kumar Kedia, JCIT

Section 133(6)Section 142(1)Section 143(2)Section 271(1)(c)Section 271BSection 44A

Nalini Tukaram Nikam, Pune vs. ITO Ward 2(3), Pune

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

ITA 2747/PUN/2024[2017-18]Status: DisposedITAT Pune30 Oct 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2747/Pun/2024 Assessment Year : 2017-18

For Appellant: Shri Sharad ShahFor Respondent: Shri Harish Bist

Section 127Section 143(2)Section 143(3)Section 250Section 57

individual and income of Rs.5,67,960/- declared in the return of income for A.Y. 2017-18 on 05.08.2017. Case selected for Limited Scrutiny through CASS for the reason of “Deduction against income from other sources’ followed by validly serving statutory notices u/s.143 ... this ground. Ground 3:- The order passed by the AO is without jurisdiction and be declared null and void. My case was selected for Limited Scrutiny through CASS and a notice u/s 143(2) was issued on 11-08-2018 by ACIT, Circle 7. Thereafter, the case was assigned

Sachin Bhagwanrao Joshi, Palam vs. ITO Ward-1, Parbhani

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

ITA 2634/PUN/2024[2020-21]Status: DisposedITAT Pune30 Oct 2025AY 2020-21

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Bashiruddin ShaikhFor Respondent: Shri Harshit Bari

Section 143(2)Section 143(3)Section 44A

income of Rs.2,98,905/-. Assessee has also shown agricultural income of Rs.38,26,580/-. The case was selected for limited scrutiny to examine the issue of agricultural income shown by the 2 assessee. Statutory notices u/s 143(2), 142(1) and show cause notice were issued to the assessee

Sreeleathers Limited, Kolkata vs. D.C.I.T., Circle - 8(2), Kolkata

ITA 1806/KOL/2025[2017-2018]Status: DisposedITAT Kolkata30 Oct 2025AY 2017-2018

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Rajesh Kumar

Section 1Section 119Section 142(1)Section 143(2)Section 143(3)Section 14A

Company, which filed its return of income electronically on 30.10.2017 declaring total income of Rs.20,85,66,570/-. The case was selected for limited scrutiny (CASS) assessment as per existing norms. Accordingly notices under section 143(2) of the Income Tax Act, 1961 was issued and served through the departmental

Devikarani Rajeswaran, Vellore vs. ITO, Ward-1, Vellore

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

ITA 2197/CHNY/2025[2017-18]Status: DisposedITAT Chennai30 Oct 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.2197/Chny/2025 िनधा:रण वष: /Assessment Year: 2017-18

For Appellant: Shri Abhishek Murali, C.A HIFor Respondent: Shri Nishanth Rao, JCIT

Section 143(3)Section 69A

filed her return of income for the A.Y 2017-18 on 07.10.2017, admitting total income of Rs.3,49,840/-. The case was selected for limited scrutiny under CASS for the reason that the assessee has made cash deposits of Rs.17,81,000/- during demonetization period. The assessee has explained

Renukamba, Bangalore Urben vs. Income-Tax Officer, Ward- 3(3)(1), Bangalore, Bengaluru Urban

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

ITA 1847/BANG/2025[2017-18]Status: DisposedITAT Bangalore30 Oct 2025AY 2017-18

Bench: Shri Prashant Maharishiassessment Year : 2017-18

For Appellant: Shri P R Suresh, CAFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing Counsel

Section 115BSection 143Section 143(2)Section 143(3)Section 69

individual, who filed his return of income on 29.3.2018 at a total income of Rs.3,92,450. The return was picked up for limited scrutiny for verifying the investment in immovable property and cash deposit during the demonetization period. Notice u/s. 143(2) of the Act was issued

Income Tax Officer, Ward-7(2)(3), Bengaluru vs. Mohammed Farooq Kanana, Bengaluru

In the result, appeal filed by the Revenue is dismissed

ITA 1509/BANG/2025[2020-21]Status: DisposedITAT Bangalore30 Oct 2025AY 2020-21

Bench: Shri.Laxmi Prasad Sahu & Shri.Soundararajan Kassessment Year : 2020-21 Ito, Vs. Mr. Mohammed Farooq Kanana, 6 9Th Cross, H Siddaiah Road, Ward – 7(2)(3), Bangalore. Bangalore – 560 027, Karnataka. Pan : Abvpm 1212 A Appellant Respondent Assessee By : Shri. Thirumala Naidu, Ca Revenue By : Shri. Subramanian S, Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 27.10.2025 Date Of Pronouncement : 30.10.2025

For Appellant: Shri. Thirumala Naidu, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore

Section 147Section 250

case are that assessee filed return of income on 01.02.2021 declaring total income of Rs.48,58,140//-. The case was selected for limited scrutiny under CASS for the following reasons: i. Large agricultural income ii. Agricultural income 5. Accordingly notice under sections

ACIT, Cir.20(1), Mumbai vs. Girish Shamji Chheda, Mumbai

In the result, the revenue's appeal is dismissed

ITA 3123/MUM/2025[2020-21]Status: DisposedITAT Mumbai30 Oct 2025AY 2020-21

Bench: Shri Pawan Singh & Smt.Renu Jauhri

For Appellant: Shri Fenil Bhatt, AdvFor Respondent: Shri Swapnil Choudhary- Sr. AR

Section 143(3)Section 250Section 36(1)(iii)Section 57Section 68

assessee derives income from the proprietory business in the name of M/s. Viraj Highway Inn. The case was selected for limited scrutiny and after considering the partial details filed by the assessee, the assessment was completed vide order u/s.143(3) r.w.s 144B at an income ... that ld. AO had violated the Principle of consistency and ignored past history of the case. Secondly, the ld. AO exceeded the scope of limited scrutiny by changing the head of the income. Thirdly, the assessee own funds and personal capital was much more then the loans taken

Sameer Ramesh Vashi, Mumbai vs. The Principal Commissioner of Income Tax, Mumbai-17, Mumbai

In the result, appeal of the assessee is allowed

ITA 164/MUM/2025[2018-2019]Status: DisposedITAT Mumbai30 Oct 2025AY 2018-2019

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2018-19 Sameer Ramesh Vashi Vs The Principal Commissioner 702, Samrock Apartment, C.D. Of Income Tax, Barfiwala Road, Andheri-West, Mumbai-17 Mumbai - 400058 [Pan: Aaapv6356Q] Appellant Respondent Present For: Assessee : Dr. K. Shivaram, Sr. Advocate & Shri Rahul Hakani, Advocate Revenue : Shri Satyaprakash R. Singh, Cit Dr Date Of Hearing : 06.08.2025 Date Of Pronouncement : 30.10.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Revisionary Order Of Pcit, Mumbai–17, Vide Order No. Itba/Com/F/17/2024- 25/1070374871(1), Dated 14.11.2024 Passed U/S. 263 Against The Assessment Order By National E-Assessment Centre, Delhi, U/S.143(3) R.W.S. 143(3A) & 143(3B) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 14.03.2023 For Ay 2018-19. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. The Pcit, Mumbai-17 Erred In Passing Order U/S 263 & Holding That Order Passed U/S 143(3) Dt 24-03-2021 Is Erroneous & Prejudicial To The Interest Of Revenue & Hence Directed The Ao To Reframe The Assessment.

For Appellant: Dr. K. Shivaram, Sr. Advocate and Shri Rahul Hakani, AdvocateFor Respondent: Shri Satyaprakash R. Singh, CIT DR

Section 142(1)Section 143(2)Section 143(3)Section 263

PCIT also erred in not appreciating the fact that the scrutiny u/s 143(3) for the above year was "Limited Scrutiny" as mentioned in notice u/s 143(2) dt 23-09-2019 and therefore the AO was not required to go beyond the issue raised in the limited scrutiny ... house property and from other sources after setting of current business loss of Rs.1,24,19,223/-. Case of the assessee was selected for limited scrutiny under CASS to verify - i. business loss ii. agriculture income. 3.1. Ld. AO in the course of assessment proceedings issued notices

Ravi Yantriki Udyog Private Limited, Pune vs. ITO Ward (5)(4), Pune

In the result, the appeal of the assessee is allowed

ITA 1588/PUN/2025[2015-16]Status: DisposedITAT Pune29 Oct 2025AY 2015-16

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Department byFor Respondent: Date of hearing

Section 133(6)Section 143(2)Section 194C

assessee filed its return of income on 13.05.2016 declaring total income at Rs.14,44,000/-. The case was selected for limited scrutiny under CASS with reason ‘Receipts u/s 194C and 194J of the Income Tax Act, 1961 (the “Act”) (as per 26AS) are more than the receipts shown

Arjun Shetty, Mangaluru vs. Income Tax Officer, Tps, Circle - 1(1), Mangaluru

In the result, appeal filed by the assessee is allowed

ITA 61/BANG/2025[2018-19]Status: DisposedITAT Bangalore29 Oct 2025AY 2018-19

Bench: Shri.Laxmi Prasad Sahu & Shri.Keshav Dubeyassessment Year : 2018-19 Arjun Shetty, Vs. Ito, 16-6-393/9 Shubha Krishna Building, Ward – Tps, Highland Falnir, Mangalore - 575002. Circle – 1(1), Pan :Ainps5294H Mangalore. Appellant Respondent Assessee By : S/Shri. Pranav G Ambekar, V. Narendra Sharma, Advocates Revenue By : Shri. Nilanjan Dey,Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 15.09.2025 Date Of Pronouncement : 29.10.2025

For Appellant: S/Shri. Pranav G Ambekar, V. Narendra Sharma, AdvocatesFor Respondent: Shri. Nilanjan Dey,JCIT(DR)(ITAT), Bangalore

Section 10Section 10(1)Section 143(2)Section 143(3)Section 250

share is 25%. Assessee filed return of income on 17.09.2018 admitting total income of Rs.1,00,38,530/-. The case was selected for limited scrutiny under CASS. Accordingly, notice under section 143(2) of the Act dated 23.09.2019 was Page 2 of 16 issued to the assessee to verify ... income and it was a bonafide mistake which resulted in paying excess taxes. 9. The return filed for AY 2018-19 was selected for limited scrutiny under CASS for the reason of “Large Agricultural income”. The learned Assessing Officer (hereinafter referred to as the learned “AO”) issued notices under section

Yedapadavu Vyavasaya Seva Sahakara Sangha Niyamitha, Yedapadavu vs. Income Tax Officer, Mangaluru

In the result, both the appeals filed by the assessee are allowed

ITA 1919/BANG/2025[2018-19]Status: DisposedITAT Bangalore29 Oct 2025AY 2018-19

Bench: Shri Prashant Maharishi

For Appellant: Shri Sriram V. Rao, CA

Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

showing gross total income of Rs.36,73,878 and claimed deduction u/s. 80P of the same amount. The return was selected for limited scrutiny for verifying the investments etc. and deduction under Chapter VIA of the Act. The assessee has claimed deduction of Rs.36