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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Allied Concepts India Private Limited, Delhi vs. ITO Ward-2(1), Delhi

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

ITA 2407/DEL/2025[2017-2018]Status: DisposedITAT Delhi26 Sept 2025AY 2017-2018

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.2407/Del/2025 िनधा"रणवष"/Assessment Year: 2017-18 बनाम Allied Concepts India Pvt. Ltd., Income Tax Officer, C/O Dr. Kapil Goel, Adv. Vs. Ward 2(1), F-26,/124, Sector-7, Rohini, Delhi. Delhi. Pan No.Aaica9865C अपीलाथ" Appellant ""यथ"/Respondent

Section 115BSection 143(2)Section 145Section 148Section 250Section 37Section 68

vehemently submitted that the notice u/s 143(2) of the Act issued to the assessee did not .specify whether it was a limited scrutiny or a complete scrutiny or a compulsory manual scrutiny. The Id. AR submitted that the CBDT has issued specifically provided vide instruction no. F. No. 225/157/2017/ITA-II

Balbir Singh, New Delhi vs. ACIT, Circle 43(1), Civic Center

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

ITA 1097/DEL/2024[2017-18]Status: DisposedITAT Delhi26 Sept 2025AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.1097/Del/2024 िनधा"रणवष"/Assessment Year: 2017-18 बनाम Balbir Singh, Acit, B-360, New Kanchan Road Apartment, Vs. Circle-43(1), Dwarka, New Delhi. Minto Road, New Delhi. Pan No.Edvps8264Q अपीलाथ" Appellant ""यथ"/Respondent

Section 119Section 143(2)

vehemently submitted that the notice u/s 143(2) of the Act issued to the assessee did not .specify whether it was a limited scrutiny or a complete scrutiny or a compulsory manual scrutiny. The Id. AR submitted that the CBDT has issued specifically provided vide instruction no. F. No. 225/157/2017/ITA-II

Vijay Singh Chauhan, Noida vs. ITO, Ward-2(5), Noida

The appeal of the assessee is hereby dismissed

ITA 2561/DEL/2023[2015-16]Status: DisposedITAT Delhi26 Sept 2025AY 2015-16

Bench: Shri Sudhir Pareek & Shri Avdhesh Kumar Mishravijay Singh Chauhan, Income Tax Officer, House No.-193, Gali No.-3, Vs. Ward- 2(5), Noida, Village Chhalera, Sector-44, Uttar Pradesh, Noida, Uttar Pradesh India. India. Pan No: Aeipc4637E Appellant Respondent Assessee By : Sh. Naveen Kumar, Adv. Revenue By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing: 01.07.2025 Date Of Pronouncement: 26.09.2025 Order Per Sudhir Pareek, Jm: The Aforetitled Appeal Has Been Preferred Against The Order Of National Faceless Appeal Centre, Delhi [Hereinafter, In Short, ‘Cit(A)’] Dated 17.07.2023 For Ay 2015-16, By Which Appeal Of The Assessee Was Dismissed.

For Appellant: Sh. Naveen Kumar, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 10(37)Section 143(2)Section 28Section 34

Assessment Year 2015-16 on 04.08.2016, claiming refund of Rs.1,33,93,740/-. Thereafter, case was selected through CASS for limited scrutiny, on the reasons as mentioned below. Vijay Singh Chauhan vs. ITO (i)Whether interest income has been correctly shown in the Return of Income. (ii) Whether refund claim

DCIT Circle-13(2), New Delhi vs. Jus Scriptum Magnus Pvt Ltd, New Delhi

In the result, we dismiss the appeal filed by the Revenue

ITA 8259/DEL/2019[2016-17]Status: DisposedITAT Delhi26 Sept 2025AY 2016-17
For Appellant: Shri Pramod Jain, CAFor Respondent: Shri Harpreet Kaur Hansra, Sr. DR
Section 133(6)Section 143(2)Section 56(2)(viib)

return of income was filed for AY 2016-17 on 17.10.2016 declaring loss of Rs.1,36,05,019/-. The case was selected for limited scrutiny under 2 CASS for the reason “Large share premium received during the year in order to verify applicability of section 56(2)(viib ... government agency named “PNB Investment Services Limited” for arranging private equity and finding suitable investors for their company. 3. The case was selected for Limited scrutiny and notice was sent u/s 143(2) which was duly complied from time to time. 4. The Appellant Company has issued 8438 shares

Mahendra Kumar Dheer, Tikamgarh vs. Income Tax Officer Ward, Tikamgarh

In the result, the appeal of the assessee is allowed

ITA 39/JAB/2025[2017-18]Status: DisposedITAT Jabalpur25 Sept 2025AY 2017-18

Bench: Shri Kul Bharatassessment Year: 2017-18 Mahendra Kumar Dheer, V. Income Tax Office Ward Amar Shanti Vinod Kunj Tigela, Near Utsav Bhawan, Opp Tikamgarh, Opp. Supermarket Collectorate Jhansi Road, Ganjipura Jabalpur-472001. Tikamgarh-472001. Pan: Arhpd3516G (Appellant) (Respondent) Appellant By: Shri Abhijeet Shrivastava, Advocate. Respondent By: Shri N.M. Prasad, Sr. Dr-1 Date Of Hearing: 18 09 2025 Date Of Pronouncement: 25 09 2025 O R D E R

For Appellant: Shri Abhijeet Shrivastava, AdvocateFor Respondent: Shri N.M. Prasad, Sr. DR-1
Section 143(2)Section 143(3)Section 69A

retired Government Employee and had filed his return of income on 13.03.2018, declaring total income of Rs.3,94,440/-. The case was selected for limited scrutiny on the issue of ‘Cash deposit during demonetization period”. A notice u/s 143(2) of the Income Tax Act, 1961 (“Act”, for short

Dulhe Ram Meena, Jaipur vs. DCIT Circle 1, Jaipur

Appeal is allowed

ITA 72/JPR/2025[2023-24]Status: DisposedITAT Jaipur25 Sept 2025AY 2023-24

Bench: SHRIGAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Rohan Sogani, CAFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT-DR
Section 143(1)Section 199Section 37B

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

Javidbhai Ahemadbhai Mansuri, Patan vs. The ITO, Ward-1, Patan

In the result, the appeal of the assessee is allowed

ITA 1194/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad25 Sept 2025AY 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblejavidbhai Ahemadbhai Mansuri, Income Tax Officer, Vs. Prop. Aamil Surgical Hospital, Ward -1, Subhadranagar, Near C.T. Point, Patan Patan-384265 [Pan : Agnpm 6086 B] (Appellant) .. (Respondent) Appellant By : Shri Ganta Manoj Kumar G., Ca Respondent By: Shri B.P. Srivastava, Sr Dr Date Of Hearing 23.09.2025 Date Of Pronouncement 25.09.2025 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

For Appellant: Shri Ganta Manoj Kumar G., CAFor Respondent: Shri B.P. Srivastava, Sr DR
Section 250Section 56(2)Section 56(2)(x)

specific ground No.1 contesting AO's jurisdiction to take up issue other than the issue of investment for which the assessment was selected for limited scrutiny, without permission of competent authority, and wrongly stating that grounds No. 1 to 6 relate to addition made ... cancelled.” 3. Heard the arguments of both the parties and perused the material available on record. 3.1 The case was selected for Limited Scrutiny to enquire into the investment in properties. The Assessee has purchased a property for Rs.29,96,836/- which has been registered at a stamp duty value

Bhagdeshwar Nagari Sahakari Patsanstha Maryadit, Pune vs. ITO Ward 10(1), Pune

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

ITA 1613/PUN/2025[2018-19]Status: DisposedITAT Pune25 Sept 2025AY 2018-19

Bench: Shri R. K. Pandaassessment Year : 2018-19

For Appellant: Shri Sanjay SuryavanshiFor Respondent: Ms. Sailee Dhole, JCIT
Section 80PSection 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)

year declaring total income of Rs.98,960/- after claiming deduction of Rs.30,14,289/- u/s 80P of the Act. The case was selected for limited scrutiny. During the course of assessment proceedings the Assessing Officer noted that the assessee has claimed deduction u/s 80P of the Act, the details

Income Tax Officer, Mumbai vs. K K Ventura, Mumbai

In the result, the appeal of the Revenue stands

ITA 5331/MUM/2024[2018-19]Status: DisposedITAT Mumbai25 Sept 2025AY 2018-19
Section 133(6)Section 143(3)Section 144BSection 260Section 68

return of income on 30/09/2018, which was subsequently revised on 25/01/2019 declaring total income of ₹18,91,800/-. The case was selected for limited scrutiny on the issues of (i) sharp increase in unsecured loans during the year, (ii) substantial squared-up loan transactions, and (iii) borrowings from persons

Paladugu Reshma, Vijayawada vs. Income Tax Officer, Ward-2(3), Vijayawada

In the result, appeal of the assessee is partly allowed

ITA 268/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam24 Sept 2025AY 2017-18

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.268/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2017-18) Paladugu Reshma V. Income Tax Officer – Ward – 2(3) D.No. 57-7-11 Income Tax Office New Postal Colony Cr Building, 1St Floor, Annex Kakatiya Clinic Road M.G.Road, Vijayawada Patamata, Vijayawada - 520010 Andhra Pradesh [Pan: Amupp5831A] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

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

revised return of income for the A.Y.2017-18 on 03.08.2017 admitting a total income of Rs.3,56,360/-. Subsequently, the case was selected for limited scrutiny to verify the cash deposits made during demonetization period. A notice under section 143(2) of the Act dated 08.08.2018 was issued and served. Subsequently

S K N Sikshan Sansthan, Bhadhadhar vs. Dy. Commissioner Income Tax (Central)-1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 445/JPR/2025[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16

Bench: Shri Gagan Goyal & Shri Narinder Kumarskn Shikshan Sansthan, 1, N. H. 11 Bhadhadar Sikar 332 315 Pan No.: Aamts 1103L ...... Appellant Vs.

For Appellant: Mr. Shafi Mohammad, Adv., Ld. ARFor Respondent: Mr. Gautam Singh Choudhary, Addl. CIT
Section 10Section 115BSection 12ASection 143(3)Section 147Section 148Section 250Section 57

trust filed its return of income on 27.03.2016 declaring total income at Rs. 2,47,979/-. The case of the assessee was selected for limited scrutiny through CASS for verification of large deduction claimed u/s. 57 of the Act. Issue of deduction u/s. 57 of the Act was investigated

Vitthaldas Nathubhai Shah, Ahmedabad vs. The Pr. CIT, Ahmedabad-3, Ahmedabad

In the result, the appeal of the assessee stands allowed

ITA 823/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad24 Sept 2025AY 2020-21

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2020-21 Vitthaldas Nathubhai Shah Vs. The Pr.Cit-3 1St Floor, Tax Planning House Vejalpur Above Usmanpura Underbridge Ahmedabad. Ahmedabad 380013. Pan : Acwps 4622 C (Applicant) (Responent) : Shri Mukesh Patel, Ar Assessee By : Shri Sher Singh, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 23/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 24/09/2025 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri Sher Singh, CIT-DR
Section 132Section 142(1)Section 143(3)Section 263Section 80G

return of income for the AY 2020-21 on 05/02/2021 declaring total income of Rs.1,01,09,280/-. The case was selected for limited scrutiny under CASS with the specific reason of verification of deductions claimed under Chapter VI-A of the Act. 2 2.2 During the course of assessment

The Nashik Jilha Mahila Sahakari Bank Limited, Nashik vs. ACIT, Circle 1, Nashik

In the result, the appeal of the appellant is dismissed

ITA 1373/PUN/2025[2017-18]Status: DisposedITAT Pune24 Sept 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sanket JoshiFor Respondent: Shri Manish Kumar
Section 147Section 250

furnished on 15.10.2016 declaring income of Rs.46,61,040/- and Rs.45,24,620/-. After the case being selected for Limited Scrutiny through CASS, ld. Assessing Officer (AO) concluded the assessments u/s.147 r.w.s.144 r.w.s.144B of the Act evenly 27.03.2022 and assessed income at Rs.94,59,633/- and Rs.1

The Nashik Jilha Mahila Sahakari Bank Limited, Nashik vs. ACIT, Circle 1, Nashik

In the result, the appeal of the appellant is dismissed

ITA 1372/PUN/2025[2016-17]Status: DisposedITAT Pune24 Sept 2025AY 2016-17

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sanket JoshiFor Respondent: Shri Manish Kumar
Section 147Section 250

furnished on 15.10.2016 declaring income of Rs.46,61,040/- and Rs.45,24,620/-. After the case being selected for Limited Scrutiny through CASS, ld. Assessing Officer (AO) concluded the assessments u/s.147 r.w.s.144 r.w.s.144B of the Act evenly 27.03.2022 and assessed income at Rs.94,59,633/- and Rs.1

Mahendra Prakash Pawar, Pune vs. CIT(A)-2, Chennai

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

ITA 1304/PUN/2025[2017-18]Status: DisposedITAT Pune24 Sept 2025AY 2017-18

Bench: Dr.Manish Borad

For Appellant: Shri Sharad Vaze and Shri Amod VazeFor Respondent: Shri Manoj Tripathi
Section 143(2)Section 143(3)Section 250Section 69C

Agri Marketing Board, Pune. Income of Rs.7,93,910/- declared in the return for A.Y. 2017-18 furnished on 20.05.2017. Case selected for Limited Scrutiny under CASS for the reason of “Credit Card payment”. Statutory notices were issued and duly served upon the assessee u/s.143

Pranoo Financial Services Private Limited, Mumbai vs. DCIT, Circle 13(1)(2), Mumbai

ITA 4580/MUM/2025[2017-18]Status: DisposedITAT Mumbai24 Sept 2025AY 2017-18

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Vipul Joshi & Ms. Sruti KalyanikarFor Respondent: Shri Virabhadra S. Mahajan
Section 143(3)Section 250Section 56(2)(viib)

loans. For the Assessment Year 2017-2018, the Assessee filed return of income on 31/01/2018. The case of the Assessee was selected for limited scrutiny in respect of the issuance of shares at premium. The Assessing Officer noted that the Assessee had issued 1,56,500 equity shares of face

Rajnish Wellness Limited, Mumbai vs. ITO, Mumbai

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

ITA 3471/MUM/2025[2018-19]Status: DisposedITAT Mumbai24 Sept 2025AY 2018-19

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2018-19 Rajnish Wellness Limited, Income Tax Officer, 6Th Floor, Ward-5(3)(1), Navjivan Commercial, Vs. Aayakar Bhavan, Lamington Road, Mumbai-400020. Mumbai Central, Mumbai-400008. Pan : Aahcr3491G (Appellant) (Respondent) For Assessee : None For Revenue : Shri Annavaram Kosuri, Sr.Dr Date Of Hearing : 23-09-2025 Date Of Pronouncement : 24-09-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 25-03-2025, Pertaining To Assessment Year (Ay) 2018-19. 2. Briefly The Facts Of The Case Are That The Assessee Filed Its Return Of Income Which Was Selected For Limited Scrutiny To Verify The Genuineness Of The Large Scale Promotion Expenses. Notices U/S. 143(2) & 142(1) Of The Income Tax Act, 1961 („The Act‟) Were Issued Calling For The Necessary

For Appellant: NONEFor Respondent: Shri Annavaram Kosuri, Sr.DR
Section 143(2)Section 144Section 37(1)

Year (AY) 2018-19. 2. Briefly the facts of the case are that the assessee filed its return of income which was selected for limited scrutiny to verify the genuineness of the large scale promotion expenses. Notices u/s. 143(2) and 142(1) of the Income

Simmi Batra, New Delhi vs. Income Tax Officer Ward-32(5), New Delhi

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

ITA 6143/DEL/2024[2015-16]Status: DisposedITAT Delhi24 Sept 2025AY 2015-16

Bench: SHRI ANUBHAV SHARMA (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 54Section 54BSection 54F

under appeal, filed her return of income on 07.09.2015 declaring total income at Rs.11,44,220/-. The case of the assessee was selected for limited scrutiny under CASS for the reason “Large deduction claimed u/s 54B, 54C, 54D, 54G, 54GA of Simmi Batra vs. ITO the Act”. Statutory notices were

Bhim Singh, Jaipur vs. I.T.O, Ward 4(1), Jaipur

In the result, the appeal of the assessee is allowed

ITA 740/JPR/2025[A.Y. 2017-18]Status: DisposedITAT Jaipur23 Sept 2025

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं./ITA No.740/JPR/2025 निर्धारण वर्ष/Assessment Year : 2017-18 Shri Bhim Singh C-24, Ambabari Metal Colony Jaipur - 302 023 बनाम Vs. The ITO Ward 4(1) Jaipur प्रत्यर्थी / Respondent स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: CFRPS 5909A अपीलार्थी / Appellant निर्धारिती की ओर से / Assessee by : Shri G.M. Mehta, CA राजस्व की ओर से / Revenue by: Shri Gautam Singh Choudhary, JCIT-DR सुनवाई की तारीख / Date of He

For Appellant: Shri G.M. Mehta, CAFor Respondent: Shri Gautam Singh Choudhary,JCIT-DR
Section 145(3)Section 250Section 69A

declaring total income at Rs.2,71,720/- after deduction of Rs.10,000/- under Chapter VIA (80TTA). The case of the assessee was selected for limited scrutiny assessment under CASS and accordingly notice u/s 143(2) of the Act was issued on 11-08-2018 fixing the date of hearing

Yogesh Mutha, Jaipur vs. ITO Ward 6(1), Jaipur, Ncrb, Statue Circle

The appeal is disposed of, for statistical purpose and the

ITA 536/JPR/2025[2017-18]Status: DisposedITAT Jaipur23 Sept 2025AY 2017-18

Bench: Learned Cit(A), While Challenging Assessment Order Dated 16.11.2019, Passed By The Assessing Officer, Relating To The Assessment Year 2017-18, As His Income For The Said

For Appellant: Shri Rajeev Sogani, C.AFor Respondent: Shri Gaurav Awasthi, JCIT
Section 142(1)Section 143(2)Section 143(3)Section 54Section 54F

assessment order and the reasons recorded therein. 3. Arguments heard. File perused. Brief Facts 4. Case of the assessee was selected under CASS for limited scrutiny. It led to issuance of notice u/s 143(2), on 13.08.2018 followed by a notice u/s 142(1) of the Act, on 03.05.2019 accompanied