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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Kamleshbhai Ramjibhai Dhaduk, Surat vs. ITO, Ward3(2)(6), Surat

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

ITA 867/SRT/2024[2017-18]Status: DisposedITAT Surat15 Oct 2025AY 2017-18

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

For Appellant: Shri Mayank A. Ogrivala, CAFor Respondent: Shri Ajay Uke, Ld. Sr. DR

Section 143(2)Section 144Section 250Section 69A

Income for relevant Assessment Year within due date on 19-08-2017 vide Ack. No. 179609470190817. The case of the assessee was selected for Limited Scrutiny and accordingly issued Notice U/s. 143(2) of the Income Tax Act, 1961 dated 17-08-2018 received

Sunil Singh, Kolkata vs. I.T.O., Ward - 30(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2555/KOL/2024[2018-2019]Status: DisposedITAT Kolkata15 Oct 2025AY 2018-2019

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Ito Ward 30(1), Kolkata Sunil Singh Aaykar Bhawan Dakshin, North Tangra, Dhapa Road, 2, Gariahat Road (South), Room Chowbagha South 24 Parganas, Vs. No.3, Fifth Floor, Kolkata-700053 Kolkata-700105, West Bengal West Bengal (Appellant) (Respondent) Pan No. Anbps5909E Assessee By : Shri Somnath Ghosh, Ar Revenue By : Shri S.B. Chakraborthy, Dr Date Of Hearing: 25.08.2025 Date Of Pronouncement: 15.10.2025

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri S.B. Chakraborthy, DR

Section 143(2)Section 143(3)

copy of which is available at page no.53 of the Paper Book, does not specify whether it is a limited scrutiny or a complete scrutiny or a compulsory manner scrutiny. The ld. AR submitted that the CBDT has issued specific instruction vide instruction no. F. No. 225/157/2017/ITA-II Dated

Ramasamy Dinesh, Gobichettipalayam vs. ITO, Ward-2(1), Erode

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

ITA 2008/CHNY/2025[2017-18]Status: DisposedITAT Chennai15 Oct 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri Jagadish

For Appellant: Shri G.Akash, Advocate &For Respondent: Ms. R. Anitha, Addl. CIT

Section 115BSection 143(3)Section 69A

including Long Term Capital Gain (LTCG) of Rs. 25,270/- on the sale of jewellery. The case was selected for limited scrutiny for the reason that the assessee had made cash deposits in his bank account during the demonetization period. During the course of assessment proceedings, the assessee explained

A B Propmart Pvt Ltd, New Delhi vs. ITO Ward 1(1), Delhi

In the result, appeal of the assessee is allowed

ITA 108/DEL/2025[2014-15]Status: DisposedITAT Delhi15 Oct 2025AY 2014-15

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2014-15] A B Propmart Pvt.Ltd., Vs Ito, Punjabi Bhawan, 10 Ward-1(1), Rouse Avenue, Delhi-110002. Delhi Pan-Aagca7340G Appellant Respondent Assessee By Shri Chandan Agarwal, Ca & Shri Ajay Marwah, Ca Revenue By Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing 17.07.2025 Date Of Pronouncement 15.10.2025 Order

Section 143(3)Section 250Section 56(2)Section 56(2)(viib)

year under appeal, filed its return of income at INR 4,55,600/- on 27.09.204. The case of the assessee was selected for limited scrutiny under CASS and various notices were issued which are replied by the assessee. During the year under appeal, assessee has received share premium

Mannohar Lal Hira Lal Ltd, Ghaziabad vs. ITO, Ward- 2(1)(4), Ghaziabad

In the result, the appeal of the assessee is allowed

ITA 2663/DEL/2022[2017-18]Status: DisposedITAT Delhi15 Oct 2025AY 2017-18

Bench: Shri Mahavir Singh, Hon’Bleasstt. Year : 2017-18 Mannohar Lal Hira Lal Ltd. Vs. Ito, Ward 2(1)(4) C/O Praveen K. Agarwal & Ghaziabad Associates Cgo Complex-1 D-17 Third Floor Ghaziabad-201001 Rdc Raj Nagar Ghaziabad Uttar Pradesh-201001 (Pan: Aabcm1295R) (Appellant) (Respondent) Appellant By : Shri Sidhantgoyal Ca Respondent By: Shri Ashok Kumar Pandey, Sr. Dr.

For Appellant: Shri SidhantGoyal CAFor Respondent: Shri Ashok Kumar Pandey, Sr. DR

Section 143(2)

NTPC (229 ITR 383). "1. On the facts and circumstances of the case and in law the AO has exceeded the scope of limited scrutiny without taking approval of concerned authorities in view the CBDT Instruction No. 20/2015 dated 29.12.2015 and CBDT Instruction No. 5/2016 dated 14.7.2016 read with DGIT ... notice issued by the AO u/s 143(2) of the Act dated 22- 09-2019 shows that the case was selected for "limited scrutiny" for examination of the following issues: 2 | P a g e i) Claim of any other amount allowable as deduction in schedule BP. ii) Bonus

Dilip Kantilal Kubavat, Porbandar vs. ITO WD 2(3), Porbandar

In the result, appeal filed by the assessee is allowed

ITA 522/RJT/2025[2016-17]Status: DisposedITAT Rajkot14 Oct 2025AY 2016-17

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita No.522/Rjt/2025 "नधा"रण वष"/Assessment Year :2016-17 Dilip Kantilal Kubavat Ito बनाम/ Prop. Vijay Dairy Farm, Ward 2 (3), Vs Near Ramdhun S V P Road, Porbandar 360575 Porbandar - 360575 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Azfpk8009B (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Sagar Shah, Ld. Ar राज"व क" ओर से/Revenue By : Shri Dheeraj Kumr Gupta, Ld. Sr-Dr सुनवाई क" तार"ख /Date Of Hearing : 09/09/2025 घोषणा क" तार"ख /Date Of Pronouncement : 14 /10/2025 आदेश/Order Per, Dr. Arjun Lal Saini, A.M The Present Appeal Has Been Filed By The Assessee, Against The Order Passed By The Learned Commissioner Of Income Tax (Appeal) [Hereinafter Referred To As “Cit(A)”], Dated 21.03.2025, Arising In The Matter Of Assessment Order Passed U/S 143(3) Of The Income Tax Act, 1961 (Here-In-After Referred To As “The Act”) Relevant To The Assessment Year 2016-17. 2. In This Appeal, The Assessee Has Raised Multiple Grounds Of Appeal. However, The Solitary Grievance Of The Assessee Is That The Ld Cit(A) Erred In Not To Consider The Basic Fact That The Assessee Has Gifted The Property To His Sister In Law (Younger Brother'S Wife) That Is, To A Relative For A Consideration Dilip Kantilal Kubavat

For Appellant: Shri Sagar Shah, Ld. ARFor Respondent: Shri Dheeraj Kumr Gupta, Ld. Sr-DR

Section 143(1)Section 143(2)Section 143(3)Section 271(1)(c)Section 50C

return of income was processed u/s 143(1) of the 1.T. Act, accepting the returned income. The assessee`s case was selected under limited scrutiny assessment by CASS and notice u/s 143(2) of the Income-tax Act, 1961 was issued by the assessing officer on 09.08.2018 and served

DCIT- 27(2), Mumbai, Vashi, Navi Mumbai vs. Nayan Builders, Ghatkopar East, Mumbai

In the result, the appeal filed by the revenue is dismissed in above

ITA 4039/MUM/2023[201819]Status: DisposedITAT Mumbai14 Oct 2025

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhan

Section 115BSection 250Section 68

business of real estate and has shown income from business or profession and income from other sources. The case was selected for limited scrutiny through CASS under faceless assessment scheme (FAS) to verify i) Income from Real Estate Business, ii) Unsecured Loans and iii) Business Expenses. Regarding the unsecured loan

Income Tax Officer, Ward-4(2), Jalandhar, Civil Lines vs. Sh. Barjesh Singhal, Modern Colony

In the result, the appeal filed by the revenue is allowed for statistical purpose

ITA 363/ASR/2024[2016-17]Status: DisposedITAT Amritsar13 Oct 2025AY 2016-17

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: None (Written submission)

Section 142(1)Section 143(3)Section 147Section 148Section 250

filed his return of income for A.Y. 2016-17 on 04/08/2016, declaring a total income of Rs. 6,87,880/-, which was selected for limited scrutiny under CASS, and after necessary enquiries and verification of some documents filed by the assessee in response to notice u/s 142(1), the assessment

Anupam Sharma, Jaipur vs. ITO Ward 1(3), Jaipur

In the result, the appeal of the assessee is dismissed

ITA 765/JPR/2025[2016-17]Status: DisposedITAT Jaipur13 Oct 2025AY 2016-17

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyalanupam Sharma, Flat No. 1-994 Block No. B-24, Rangoli Garden Near Vaishali Nagar, Jaipur 302 021 Pan No.: Awpps 0767D ...... Appellant

For Appellant: Mr. Ashish Khandelwal, CA, Ld. ARFor Respondent: Mr. Dharam Singh Meena, JCIT- Ld. DR

Section 143(3)Section 250Section 5

return was processed under section 143(1) of the Income-tax Act, 1961. Subsequently, the case was selected for limited scrutiny on the specific issue: “Whether the investments and income relating to securities (derivatives) transactions are duly disclosed.” 3. During the course of scrutiny assessment, the Assessing Officer (AO) called

Nirmal Kumar Dugar, Jaipur vs. Income Tax Officer Ward 2(1) Jaipur, Jaipur

Appeal is allowed

ITA 130/JPR/2025[2016-2017]Status: DisposedITAT Jaipur13 Oct 2025AY 2016-2017

Bench: This Appellate Tribunal.

For Appellant: Sh. Sauravh Harsh, Adv., Ld. ARFor Respondent: Shri Gaurav Awasthi, JCIT, Ld. DR

Section 142(1)Section 143(2)Section 43(5)Section 44A

income relating to the Assessment Year 2016-17, the assessee declared his total income as “Nil”. Case of the assessee was selected for limited scrutiny through CASS. In this regard, notice under section 143(2) of the Act was served upon the assessee. 3 Nirmal Kumar Dugar, Jaipur During said

Ceigall India Limited, Ludhiana vs. Principal Commissioner of Income Tax, Ludhiana

In the result, the appeal of the assessee stands allowed

ITA 540/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh13 Oct 2025AY 2020-21

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Tarundeep Kaur, CIT, DR(Virtual)

Section 143(2)Section 143(3)Section 263

grounds mentioned in the memo of appeal. 3.1 During the course of the hearing, the learned AR submitted that the case was selected for limited scrutiny, the AO raised specific queries on all six CASS issues, and the assessee filed detailed written replies with supporting evidence. 3.2 The AO applied ... argued that this was never a CASS issue. Without converting the case into “complete scrutiny”, the PCIT could not travel beyond the limited scrutiny scope. Moreover, purchases were reflected in audited accounts and routed through banking channels. 3.11 In sum, the AR contended that the AO had raised queries, assessee

Aditi Steels, Bhavnagar vs. The Dy. CIT, Circle-1, Bhavnagar

In the result, the appeal of the assessee is allowed

ITA 370/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamble

For Appellant: Shri D.K Parikh, ARFor Respondent: Shri Sudhakar Verma, Sr.DR

Section 143(1)Section 143(2)

acknowledgment number 311908021280918. The return was processed under section 143(1) of the Income Tax Act, 1961 on 15.05.2019. The case was selected for limited scrutiny through “CASS” for the reason “Income from Scrap”. Statutory notice under section 143(2) dated 22.09.2019 was issued to the assessee through the ITBA

Annapurna Nagari Sahkari Pathsanstha Maryadit, Jalgaon vs. ITO, Ward 1(4), Jalgaon

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

ITA 314/PUN/2025[2018-19]Status: DisposedITAT Pune10 Oct 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19

For Appellant: Shri Nikhil S PathakFor Respondent: Ms. Richa Gulati (virtually)

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

providing credit facilities to its members. It filed its return of income on 13.10.2018 declaring total income of Nil. The case was selected for limited scrutiny under CASS. Accordingly statutory notices u/s 143(2) and 142(1) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) were

Pawan Kumar Sharma, New Delhi vs. Assistant Director of Income Tax, Banglore

In the result, appeal of the assessee in ITA No

ITA 2509/DEL/2025[2020-21]Status: DisposedITAT Delhi10 Oct 2025AY 2020-21

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: Shri Sumit Lalchandani, AdvFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR

Section 139(1)Section 143(1)Section 234ASection 36(1)Section 36(1)(va)Section 37

because of AIR Information under CASS and the Assessing Officer cannot go beyond the reasons for scrutiny selection and such cases are called Limited Scrutiny cases and only the remaining returns are taken up for complete scrutiny u/s 143(3) of the Act. 13.2 Meaning thereby, that exercise of power

Huawei Telecommunications (India) Company Pvt. Ltd., Gurgaon vs. DCIT, Circle- 2(1), Gurgaon

In the result, the appeal of assessee is allowed

ITA 8260/DEL/2018[2014-15]Status: DisposedITAT Delhi10 Oct 2025AY 2014-15

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2014-15 Huawei Telecommunications Vs. Dcit, (India) Company Pvt. Ltd., Circle 2(1), 7Th Floor, Tower-A, Spaze-1- Gurgaon Tech Park, Sohna Road, (Haryana) Gurgaon, Haryana Pin: 122 001 Aabch1376E (Appellant) (Respondent)

For Appellant: S/Shri Deepak Chopra and AnkurFor Respondent: Shri Dharm Veer Singh, CIT (DR)

Section 142(1)Section 143(2)Section 144C(1)Section 92CSection 92C(3)

assessee company filed return of income declaring total income as ‘Nil’ on 30.11.2014. The return was revised on 30.03.2016. The case was selected for ‘limited scrutiny’ through CASS. Notice under Section 143(2) dated 31.08.2015 was issued. Notices under Section 142(1) of the Act along with questionnaire were issued

Ratanshi, Rajkot vs. Income Tax Officer, Morbi

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

ITA 171/RJT/2024[2017-18]Status: DisposedITAT Rajkot09 Oct 2025AY 2017-18

For Appellant: Shri Kalpesh Parekh, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 139Section 143(3)Section 250Section 69A

number 499879880250318 on 25/03/2018 declaring total income of Rs. Nil/- and also agriculture income of Rs. 2,06,609/-. The case was selected for limited scrutiny under CASS for the examination of reason "cash deposit during demonstration period". During the assessment proceedings, the assessing officer noticed that assessee has deposited

Parikh Amitkumar Mahendrabhai, Vadodara vs. The Dy.CIT, Circle-1(1)(1), Vadodara

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

ITA 1199/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad09 Oct 2025AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2015-16 Parikh Amitkumar Mahendrabhai The Dcit 6, Alaknanda Society Circle 1(1)(1) Sama, Vadodara 390 008. Vadodara. Pan : Acppp 2527 G (Applicant) (Responent) Assessee By : Shri Mehul K. Pate, Advocate Revenue By : Shri Yogesh Mishra, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 07/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 09/10/2025 आदेश/O R D E R आदेश आदेश आदेश

For Appellant: Shri Mehul K. Pate, AdvocateFor Respondent: Shri Yogesh Mishra, Sr.DR

Section 129Section 133(6)Section 142(1)Section 143(3)Section 2Section 271(1)(b)Section 54

assessee, an individual, filed his return of income on 31.10.2015 declaring total income of Rs.21,21,040/-. The case was selected for limited scrutiny under CASS. A notice under section 2 143(2) was issued on 19.09.2016 to which the assessee sought adjournment on 26.09.2016. Thereafter, notice under section

Sridhar Maramreddy, Hyderabad vs. ITO., Ward-8(1), Hyderabad

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

ITA 504/HYD/2025[2017-18]Status: DisposedITAT Hyderabad09 Oct 2025AY 2017-18

Bench: Shri Inturi Rama Raoआ.अपी.सं /Ita No.504/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2017-18) Shri Sridhar Maramreddy, Income Tax Officer, Vs. Ward 8(1), Hyderabad. Hyderabad. Pan:Bqhpm4916K (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Abhishek Murali, C.A. रधजस् व द्वधरध/Revenue By: Shri Kumar Aditya, Dr सुिवधई की तधरीख/Date Of 07/10/2025 Hearing: घोर्णध की 09/10/2025 तधरीख/Pronouncement: आदेश/Order Per Inturi Rama Rao : This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 27.01.2025

For Appellant: Shri Abhishek Murali, C.AFor Respondent: Shri Kumar Aditya, DR

declaring total income of Rs.7,12,190/- and agricultural income of Rs.4,17,300/-. ITA No.504/Hyd/2025 2 The case was selected for limited scrutiny through CASS, notice was issued by the Assessing Officer to the assessee to furnish details regarding cash deposits to the tune of Rs.25

Padmanaban Sukhumaran, Bangalore vs. ACIT, Circle-5(3)(1), Bangalore

In the result, the appeal filed by the assessee towards the interest claimed u/s

ITA 950/BANG/2025[2017-18]Status: DisposedITAT Bangalore09 Oct 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Ravishankar, AdvocateFor Respondent: Shri Subramanian S, JCIT-DR

Section 234ASection 24Section 250

assessee has claimed TDS of Rs. 27,78,701/- deducted by the employer company M/s. IBM India Pvt. Ltd. The case was selected for limited scrutiny. Subsequently, statutory notices were issued to the assessee. The assessee furnished the reply. It was noticed that the assessee has claimed deduction

Belegara Halli Nanjamari, Tiptur vs. Income Tax Officer, Ward-1, Tiptur

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

ITA 222/BANG/2025[2017-18]Status: DisposedITAT Bangalore09 Oct 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Gokul, AdvocateFor Respondent: Advocate - Standing

Section 142(1)Section 69A

individual and filed his return of income on 15/03/2018. The case was selected for scrutiny on the basis of CASS for the limited scrutiny to verify the cash deposits made during the demonetisation period. Notices were issued u/s. 142(1) for which the assessee explained that the cash deposits