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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Yedapadavu Vyvasaya Sahakara Sangha Niyamitha, Yedapadavu vs. Income Tax Officer, Ward-2(2), Mangaluru

ITA 1878/BANG/2025[2020-21]Status: DisposedITAT Bangalore29 Oct 2025AY 2020-21

Bench: Shri Prashant Maharishi

For Appellant: Respondent byFor Respondent: Shri Sriram V. Rao, CA

Section 143(3)Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

income on 24.10.2018 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.36,73,878 u/s.80P

Rama University Uttar Pradesh, Kanpur, Uttar Pradesh vs. The Assessment Unit, Delhi

The appeal is allowed

ITA 3983/DEL/2025[2020-21]Status: DisposedITAT Delhi29 Oct 2025AY 2020-21

Bench: Shri Anubhav Sharma & Shri Naveen Chandraassessment Year: 2020-21 Rama University, Vs The Assessment Unit, 100, Rama City, Delhi. Gt Road, Mandhana, Kanpur Dehat. Pan: Aadtr0638L (Appellants) (Respondents) Assessee By : Shri Ashutosh Thakur, Advocate Revenue By : Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing : 07.10.2025 Date Of Pronouncement : 29.10.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Order Dated 04.06.2025 Passed U/S 270A Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) By The Assessment Unit, Delhi (Hereinafter Referred To As The Ld. Ao).

For Appellant: Shri Ashutosh Thakur, AdvocateFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR

Section 270A

considered view that when the quantum addition has been quashed on the basis that there was error in exercising jurisdiction by expanding limited scrutiny case without due approval of the competent authority, then, no case for penalty u/s 270A of the Act survives. The appeal is allowed. The impugned penalty

Income Tax Officer, Sanjay Place Agra vs. Gunjan Gupta Batra, Noida

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

ITA 290/AGR/2025[2016]Status: DisposedITAT Agra28 Oct 2025

Bench: Shri S.Rifaur Rahman & Shri Sunil Kumar Singhincome Tax Officer, Vs. Gunjan Gupta Batra, Ward 2 (1), Agra. A - 45, Sector 26, Noida – 201 301 (Uttar Pradesh). (Pan : Abupg5419J) (Appellant) (Respondent) Assessee By : Shri Somil Agarwal, Advocate Ms. Shilpa Gupta, Ca Revenue By : Shri Shailendra Srivastava, Sr. Dr Date Of Hearing : 13.10.2025 Date Of Order : 28.10.2025

For Appellant: Shri Somil Agarwal, AdvocateFor Respondent: Shri Shailendra Srivastava, Sr. DR

Section 142(1)Section 143(3)Section 263Section 68

initiated the proceedings under section 263 of the Income-tax Act, 1961 (for short ‘the Act’) and observed that the case was selected for limited scrutiny to verify capital introduced by the assessee amounting to Rs.2,35,09,650/-. It was observed that assessee filed return of income

Marshal Security Services, Agra vs. Assistant Commissioner of Income Tax, Agra

In the result, this appeal of the assessee is allowed

ITA 131/AGR/2025[2016-17]Status: DisposedITAT Agra28 Oct 2025AY 2016-17

Bench: : Shri M. Balaganesh & Shri Sunil Kumar Singh

Section 143(1)Section 143(2)Section 144Section 250

accepting that the ‘AO' exceeded her jurisdiction in making the disallowance of Rs.1,53,70,347/- ignoring the fact that the case was selected Limited Scrutiny’ on the ground of "whether contract receipts/fees have been correctly offered for tax “and not "whether contract Income is correctly offered for Tax". Therefore ... assessee and learned Sr. DR for revenue. 6. Learned representative for assessee has submitted that the assessee’s case was selected only for ‘limited scrutiny’ to verify the issue “whether contract receipts/fees have been correctly offered to tax”. Further that the Assessing Officer had no jurisdiction to examine the following

Manish Punjabhai Odedra, Porbandar vs. Income Tax Officer Ward 2(4), Porbandar, Gujarat

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

ITA 187/RJT/2025[2015-16]Status: DisposedITAT Rajkot28 Oct 2025AY 2015-16

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

For Appellant: Shri Sagar Shah, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 69A

returned income was processed u/s 143(1) of the Income tax Act, 1961.Later on, the assessee's case was selected for limited scrutiny through CASS. Accordingly, notice u/s 143(2) was issued on 04.08.2016 and duly served upon the assessee on 10.08.2016. Subsequently, a notice

Palas Gram Sewa Sahkari Samiti Limited, Sikar vs. ITO, Sikar

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

ITA 1017/JPR/2025[2020-2021]Status: DisposedITAT Jaipur28 Oct 2025AY 2020-2021

For Appellant: Sh. Jitendra Kumar, CAFor Respondent: Sh. Gajendra Singh, Addl. CIT

Section 144Section 250Section 253(5)Section 80A(2)Section 80PSection 80P(2)(a)

taking claim of deduction u/s.80P(2)(a)(i) under chapter-VIA amounting of Rs.34,49,015/- . The case of the assessee was selected for Limited scrutiny through Computer Aided Scrutiny Selection (CASS) to verify the issue of "Deduction from Total Income under Chapter VI-A”. Ld. AO has granted various ... from Intimation Letter issued under section 143(1) of the Income Tax Act. However, during the assessment proceedings, the case having been selected for limited scrutiny under CASS for verification of deduction under Section 80P, the Learned Assessing Officer erred in passing an ex parte assessment order under Section

Ajithkumar Adinath Dhanashetti, Bijapur vs. Income Tax Officer, Ward-2, Bijapur

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

ITA 1864/BANG/2025[2017-18]Status: DisposedITAT Bangalore28 Oct 2025AY 2017-18

Bench: Shri Prashant Maharishiassessment Year : 2017-18

For Appellant: Smt. Pratibha R., AdvocateFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing Counsel

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

individual, who filed his return of income on 31.3.2018 at a total income of Rs.4,92,110. The case was selected for limited scrutiny for verification of the cash deposit during the demonetisation period. Notice u/s. 143(2) of the Act was issued on 24.9.2018. Information was called

ACIT(E) Circle -1(1) New Delhi, New Delhi vs. Harpyari Devi Welfare Society, Delhi

ITA 4361/DEL/2024[2017-18]Status: DisposedITAT Delhi28 Oct 2025AY 2017-18

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumar

Section 11Section 12ASection 13(2)Section 142(1)Section 143(2)Section 143(3)Section 80

return of income declaring Nil for the A.Y. 2017-18 on 30-10-2017. Subsequently the case of the assessee was selected for limited scrutiny under CASS and notice u/s 143(2) of the Act was issued on 18-09-2018. Thereafter notice u/s 142(1) of the Act along

Saurabh Lal, Ghaziabad vs. ITO Ward 2(2)(3), Ghaziabad

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

ITA 3144/DEL/2024[2015-16]Status: DisposedITAT Delhi28 Oct 2025AY 2015-16

Bench: Sh.Challa Nagendra Prasad & Sh.Brajesh Kumar Singhassessment Year: 2015-16 Saurabh Lal Vs. Ito 2Nd H. No. 677, Floor, Ward- 2 (2) (3) Sector-5, Vaishali, Ghaziabad Ghaziabad Pan No. Aexpl1956K (Appellant) (Respondent)

Section 144

declaring total income of Rs.4,96,120/-. The assessee during the year was engaged in export business. The case was selected for limited scrutiny under Computer Assisted Scrutiny Selection (CASS) to examine the export turnover mismatch. The assessee did not comply for the hearing notices during the assessment proceedings

Bhagwati Infraestate Private Limited, Jhansi vs. Income Tax Officer-Ward-2(3)(1), Jhansi

In the result, assessee’s appeal is allowed for statistical purposes

ITA 357/AGR/2025[2018-19]Status: DisposedITAT Agra27 Oct 2025AY 2018-19

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2018-19

Section 143(2)Section 250Section 250(6)

declaring total income as Nil, claiming current year’s losses of Rs.1,02,103 to be carried forward. Case was selected for limited scrutiny under CASS for the reason ‘large share premium received during the year (verify applicability of Sec 56(2)(viib) or any other relevant section)’. Statutory notices

Changela Mohanbhai R HUF, Near Bus Stand vs. Principal Commissioner of Income Tax, Aaykar Bhavan

In the result, the appeal of the assessee is allowed

ITA 210/RJT/2025[2020-21]Status: DisposedITAT Rajkot27 Oct 2025AY 2020-21

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

For Appellant: Shri Samir Jani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)

Section 133(6)Section 143(3)Section 263

declaring total income of Rs.19,29,090/- and agricultural income of Rs.60,87,400/-. This assessee`s case was selected for limited scrutiny under in CASS on the issue of "Large Agricultural Income". The Assessment was finalised u/s 143(3) r.w.s. 144B of the Income

M/S Nihal Projects, Kachchh vs. ITO Ward 2, Gandhidham

In the result, the appeal of the assessee is

ITA 929/RJT/2024[2017-18]Status: DisposedITAT Rajkot27 Oct 2025AY 2017-18

Section 115BSection 142(1)Section 143Section 143(2)Section 2(24)(x)Section 234ASection 274Section 43BSection 68

submitted by the ld.Counsel before the Bench. Both the notices u/s 143(2) of the Act, have not specified whether it is a limited scrutiny or a complete scrutiny or a compulsory manual scrutiny. The copy of both the notices issued u/s 143(2) dated 17/08/2018 and 23/08/2018, were submitted ... notice under section 143(2) of the Act, as the notices u/s 143(2) of the Act, have not specified whether it is a limited scrutiny or a complete scrutiny or a compulsory manual scrutiny. It is a settled law that the Circulars issued by CBDT are binding

Shri Amitkumar Jasvantlal Doshi, Surendranagar vs. The DCIT, Cir.-4 (1) (1), Ahmedabad

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

ITA 842/RJT/2024[2020-21]Status: DisposedITAT Rajkot27 Oct 2025AY 2020-21

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 842/Rjt/2024 ("नधा"रणवष" / Assessment Year: (2020-21) (Hybrid Hearing) Amitkumar Jasvantlal Doshi Cit(Appeals), Nfac-Delhi, Vs. 16, Ashok Nagar Society, Meghani Road, Dcit, Circ – 4(1)(1), Surendranagar-363001 Ahmedabad "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aazpd3668C (Appellant) (Respondent) Appellant By : Shri Krunal Karia, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 28/07/2025 Date Of Pronouncement : 27/10/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm:

For Appellant: Shri Krunal Karia, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 142(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144Section 250

income declaring total income of Rs.1,24,19,980/- was filed on 25.08.2020 for A.Y. 2020-21. Subsequently, the case was selected for limited scrutiny through CASS and the issue was reported as "Deductions from Income from other Sources" and "Agricultural income". Statutory notice u/s 143(2) of the income ... have heard both the parties and perused the material available on record. Subsequently, the Return of Income was selected for Limited Scrutiny under CASS (Computer Aided Scrutiny Selection) on issues of "Deduction from Amitkumar J. Doshi Income from Other Sources" and "Agriculture Income". For the Assessment Year

The West Godavari District Co Op Marketing Society Ltd, Eluru vs. Principal Commissioner of Income Tax-1, Visakhapatnam

ITA 356/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam27 Oct 2025AY 2020-21

Bench: Shri Balakrishnan Sshri Sandeep Singh Karhailthe West Godavari District Co-Op. Marketing Society Ltd., Eluru, 25-55, Opposite To Fire Station N.R. Pet Eluru - 534006 ............... Appellant Pan: Aaaat7717Q V/S Principal Commissioner Of Income Tax, Pcit, Visakhapatnam - 1 ……………… Respondent

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Shri M.N. Murthy Naik, CIT (DR)

Section 143(3)Section 144BSection 263Section 80PSection 80P(2)(a)Section 80P(2)(d)

filed its return of income on 29.12.2020, declaring a total income of Rs.61,14,640. The return filed by the assessee was selected for limited scrutiny under CASS, inter alia, for examining the deduction claimed under Chapter VI-A of the Act. The Assessing Officer (“AO”) vide order dated

Shivam Multispeciality and Accident Care Centre Pvt. Ltd., Pune vs. Income Tax Officer, Pune

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

ITA 696/PUN/2025[2017-2018]Status: DisposedITAT Pune27 Oct 2025AY 2017-2018

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.696/Pun/2025 धििाारण वर्ा / Assessment Year : 2017-18 Shivam Multispecialty & Accident Care Income Tax Officer, Centre Pvt. Ltd., Ward – 6(1), Pune Opp. Manali Resort, Near Dsk Dream City, Vs. Next To Loni Kalbhor Toll Naka, Pune-Solapur Mumbai Bypass Road, Fursungi, Pune-412308, Maharashtra Pan : Aapcs5482A अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Dhiraj Dandgaval Department By : Shri Akhilesh Srivastva Date Of Hearing : 06-08-2025 Date Of 27-10-2025 Pronouncement : आदेश / Order

For Appellant: Shri Dhiraj DandgavalFor Respondent: Shri Akhilesh Srivastva

Section 143(2)Section 144Section 68

assessee filed its return of income on 01.05.2018 declaring total income of Rs.13,220/-. The case of the assessee was selected under limited scrutiny through CASS for verification of share application money. Accordingly, statutory notices under section 143(2)/142(1) were issued and served upon the assessee. However

Sudam Pandurang Beldare, Pune vs. ITO, Ward-5(3), Pune

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

ITA 2028/PUN/2025[2016-17]Status: DisposedITAT Pune27 Oct 2025AY 2016-17

Bench: Dr.Manish Borad & Ms. Astha Chandra

For Appellant: NoneFor Respondent: Shri Bharat Andhale

Section 143(1)Section 143(3)Section 250

return for A.Y. 2016-17 on 12.04.2017 declaring income of Rs.10,22,440/-. Return processed u/s.143(1) of the Act. Subsequently, case selected for Limited Scrutiny for verification of Large cash deposits in savings bank account and assessee has purchased/sold one or more property during the year. Valid statutory notices

Satyam Transformers Private Limited, Aurangabad vs. ITO Ward 2(3), Aurangabad

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

ITA 1239/PUN/2025[2015-16]Status: DisposedITAT Pune27 Oct 2025AY 2015-16

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1239/Pun/2025 धििाारण वर्ा / Assessment Year : 2015-16 Satyam Transformers Private Limited, Ito, Ward-2(3), Sharadanand, Opposite Telephone Office, Aurangabad Ajabnagar, Aurangabad-431001 Vs. Pan : Aakcs4648D अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Shubham N. Rathi Department By : Shri Akhilesh Srivastva Date Of Hearing : 04-08-2025 Date Of 27-10-2025 Pronouncement : आदेश / Order

For Appellant: Shri Shubham N. RathiFor Respondent: Shri Akhilesh Srivastva

Section 143(2)Section 143(3)Section 250Section 72

assessee filed its return of income on 28.09.2015 declaring total income at Rs. Nil. The case of the assessee was selected for limited scrutiny under CASS for the following reasons: (i) Large long term Capital gain; (ii) Large business loss 2 ITA No.1239/PUN/2025, AY 2015-16 set off against others

The Salesian Sisters, Kolkata vs. ITO, Ward 1(3), Exempt, Kolkata

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

ITA 576/KOL/2025[2018-2019]Status: DisposedITAT Kolkata27 Oct 2025AY 2018-2019

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 11(2)Section 11(3)Section 12ASection 143(1)Section 143(1)(a)Section 143(3)Section 250Section 264

demand of ₹1,43,99,556/- and processed the return u/s 143(1) of the Act. Subsequently, the assessee’s case was selected for limited scrutiny and the Assessing Officer (hereinafter referred to as Ld. 'AO') completed the assessment vide order u/s 143(3) of the Act dated 17.02.2021 without

Debasish Banerjee, Kolkata vs. ITO, Ward 44(1), Kolkata

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

ITA 1047/KOL/2025[2018-2019]Status: DisposedITAT Kolkata27 Oct 2025AY 2018-2019

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2018-19 Debasish Banerjee…………….……………………….……….……….……Appellant C/O Subash Agarwal & Associates, 1, Gibson Lane, Kol- 700069.. [Pan: Agfpb3602C] Vs. Ito, Ward-44(1), Kolkata………………………………….....……...…..…..Respondent Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri Manas Mondal, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 16, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 23.04.2025 Of The National Faceless Appeal Centre [Hereinafter Referred To As The “Ld. Cit(A)”] Arising Out Of An Order Passed U/S 143(3) R.W.S. 144B Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”] Dated 30.04.2021 By Ito, Ward-44(1), Kolkata.

Section 143(3)Section 50C

assessee filed his return of income declaring total income of Rs.2,40,660/- for the year under consideration. The case was selected for limited scrutiny on the issue of “the assessee has reported sale consideration in the capital gain schedule of return of income, which is less than value

Chandapura Thimmareddy Manjunath, Bangalore Karnataka vs. Income Tax Officer Ward 4(3)(5), Bangalore, Bangalore Karnataka

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

ITA 1641/BANG/2025[2017-18]Status: DisposedITAT Bangalore27 Oct 2025AY 2017-18

Bench: Shri Prashant Maharishiassessment Year : 2017-18

For Appellant: Shri Siddesh Nagaraj Gaddi, CAFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing Counsel

Section 143(2)Section 144

that assessee has filed the return of income on 24.7.2017 at a total income of Rs.3,77,680. The return was picked up for limited scrutiny to examine the cash deposit during the demonetisation period and transaction in property. Notice u/s. 143(2) was also issued. Assessee was asked ... lower authorities. The facts show that assessee is an individual , filed his return of income of Rs.3,77,680. Selection for limited scrutiny of the case show that there are cash deposits during the demonetisation period and further cash deposits and transactions in property needs to be examined. As such