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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Sun Ark Aluminium Industries Pvt. Ltd., Virudhunagar vs. ITO, Corporate Circle, Madurai

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

ITA 2071/CHNY/2025[2018-19]Status: DisposedITAT Chennai24 Oct 2025AY 2018-19

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:2071/Chny/2025 यनिाारणवर्ा / Assessment Year:2018-19 Sun Ark Aluminium Income Tax Officer, Industries Private Limited, Vs. Corporate Circle, No.22, Chairman A, Madurai. Shanmugam Road, Sivakasi, Virudhunagar, Tamil Nadu-626 123. [Pan:Aalcs3262Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr.G.Baskar, Advocate, प्रत्यर्थीकीओरसे/Revenue By : Mr.C.P.Solomon, Jcit.

For Appellant: Mr.G.Baskar, AdvocateFor Respondent: Mr.C.P.Solomon, JCIT
Section 142(1)Section 143(2)Section 143(3)Section 263

neither erroneous nor prejudicial to the interest of the Revenue. 4. The original assessment having been carried out for a limited scrutiny, PCIT ought to have seen that the AO has completed the limited scrutiny and the PCIT ought not to have held the assessment to be erroneous invoking jurisdiction ... which stood revised on 25.03.2019 declaring total loss of Rs.3,20,43,623/-. The case of the assessee was taken up for limited scrutiny under the e-assessment scheme 2018 vide notice u/s 143(2) of the Act dated 22.09.2019 for examining the following issues:- 1). Exports / Imports 2). Duty

Razak Rowther Mohamed Saleem, Dindigul vs. ITO, Ward-1, Dindigul

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

ITA 1731/CHNY/2025[2016-17]Status: DisposedITAT Chennai17 Oct 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1731/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Razak Rowther Mohamed Saleem, Vs. The Income Tax Officer, No. 29A, Manthinapalli Vasal Street, Ward 1, Batlagundu Road, Begampur, Dindigul. Dindigul 624 002. [Pan:Acfpm9762L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. S. Vidya, C.A. ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 10.09.2025 घोषणा की तारीख /Date Of Pronouncement : 17.10.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 15.05.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2016-17. 2. The Assessee Raised 3 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is 2

For Appellant: Ms. S. Vidya, C.AFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 143(1)Section 143(2)Section 2

return of income was processed under section 143(1) of the Income Tax Act, 1961[“Act” in short]. The case was subsequently selected for "Limited scrutiny" under CASS and notice under section 143(2) of the Act dated 05.07.2017 was issued. The reason for scrutiny selection is to verify

Ramesh Verma, Moradabad vs. ITO, 2(1), Moradabad

In the result, the appeal of the assessee is allowed

ITA 5124/DEL/2024[2017-18]Status: DisposedITAT Delhi17 Oct 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalmr. Ramesh Verma, Income Tax Officer, Bhogpur Mithoni, Ward-2(1), Atal Mohalla, Mandi Chowk, Vs. Moradabad. Moradabad-244001 Uttar Pradesh. Pan-Acvpv3651M (Appellant) (Respondent) Assessee By Shri Mayank Patawarai, Adv. Shri Akash Ojha, Adv. Department By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 22/07/2025 Date Of Pronouncement 17/10/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A), In Short] Dated 18.09.2024 In Appeal No. Cit(A), Moradabad/20293/2019-20 Arising Out Of Order Passed U/S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) Dated 14.12.2019 For Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Is An Individual & Had Filed His Return Of Income On 30.03.2018 Declaring Total Income Of Rs.4,72,820/-. The Case Of The Assessee Was Selected For Limited Scrutiny Under Cass For Examination Of Cash Ramesh Verma Vs. Ito Deposits & Cash Withdrawals In The Bank Accounts. The Ao Has Observed That Assessee Is Maintaining Two Bank Accounts (I) With State Bank Of India & (Ii) With Prathma Bank. As Per The Ao, Total Cash Of Rs.71,12,000/- Were Deposited During The Year Which Were Alleged As Unexplained U/S 69A & Addition Was Made. In Addition To This, Further Addition Was Made On Account Of Other Deposit In Both The Bank Accounts.

Section 143(3)Section 69A

filed his return of income on 30.03.2018 declaring total income of Rs.4,72,820/-. The case of the assessee was selected for limited scrutiny under CASS for examination of cash Ramesh Verma vs. ITO deposits and cash withdrawals in the bank accounts. The AO has observed that assessee is maintaining ... upheld and the additions on account of other deposits in the banks was deleted by observing that the same is beyond the scope of limited scrutiny. 4. Aggrieved by the said order, the assessee is in appeal before the Tribunal by taking the following grounds of appeal

Abdul Razaque, Jabalpur vs. ACIT Circle 2(1), Jabalpur

In the result, ground no. 1 is allowed while ground nos

ITA 84/JAB/2024[2016-17]Status: DisposedITAT Jabalpur16 Oct 2025AY 2016-17

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2016-17 Abdul Razaque, Vs. Acit, 903, Badi Omti, Jabalpur, M.P. Circle-2(1), Jabalpur Pan:Afgpr9967N (Appellant) (Respondent) Assessee By: Sh. Sapan Usrethe, Advocate Revenue By: Sh. Alok Bhura, Sr. Dr Date Of Hearing: 18.09.2025 Date Of Pronouncement: 16.10.2025 O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Addl Jcit(A), Mysore, Wherein The Ld. Addl Jcit(A) Has Partly Allowed The Appeals Of The Assessee Against The Orders Of The Ld. Ao Dated 19.11.2018, Passed Under Section 143(3) Of The Income Tax Act, 1961. The Grounds Of Appeal Are As Under:- “1. The Learned Commissioner Of Income Tax (Appeal) Addl/Jaddl Jcit(A)- Mysore Was Not Justified In Deciding The Legal Ground That Case Was Selected For Limited Scrutiny Under Cass To Examine The Reasons Of (I) Return Filed After 7.11.2016' & Cash Deposit During Demonetization Period & Addition Was Made On Some Other Issue Which Was Not The Reason For Selection & Without Taking Any Approval From Higher Authorities. 2. The Learned Commissioner Of Income Tax (Appeal) Addl/Jaddl Jcit(A)-Mysore Was Not Justified In Confirming The Addition Of Rs. 4,48,584 By Ignoring All The Evidences & Documents By Simply Observing That No New Documents Were Filed Even Though Documents Which Are Filed Are Sufficient & Self-Explanatory & The Order Of Learned Cit Appeals Is Passed In A Mechanical Manner, Without Any Application Of Mind & Appears That It Was Passed With Predetermined Mind.

For Appellant: Sh. Sapan Usrethe, AdvocateFor Respondent: Sh. Alok Bhura, Sr. DR
Section 143(2)Section 143(3)Section 68

learned Commissioner of Income tax (Appeal) ADDL/JADDL JCIT(A)- Mysore was not Justified in deciding the legal ground that case was selected for limited scrutiny under CASS to examine the reasons of (i) Return filed after 7.11.2016' and cash deposit during demonetization period and addition was made on some other ... return of income for the A.Y. 2016-17 on 11.03.2018 declaring total income of Rs. 47,06,510/-. The case was selected for limited scrutiny under CASS to examine; (i) Return filed after 7.11.2016 and (ii)cash deposit during demonetization period. The ld. AO records that statutory notices under section