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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Vedic Foundation Private Limited, Delhi vs. Income Tax Officer, Ward 26(2), Delhi

Appeal is allowed

ITA 4975/DEL/2025[2017-18]Status: DisposedITAT Delhi23 Sept 2025AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 4975/Del/2025 : Asstt. Year : 2017-18 Vedic Foundation Pvt. Ltd., Vs Income Tax Officer, 43-B, First Floor, Mig Flat, Ward-26(2), Pocket-B Dilshad Garden, New Delhi-110002 New Delhi-110095 (Appellant) (Respondent) Pan No. Aaaci8590C Assessee By: None Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 23.09.2025 Date Of Pronouncement: 23.09.2025 Order This Assessee’S Appeal For Assessment Year 2017-18, Arises Against The Addl./Jcit(A), Panchkula’S Din & Order No. Itba/Apl/S/250/2025-26/1077029340(1) Dated 13.06.2025, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: NoneFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 143(2)Section 143(3)Section 69

upheld in the lower appellate proceedings, it emerges at the outset that it was a case of 2 Vedic Foundation Pvt. Ltd. “limited” scrutiny on the basis of expenses incurred for earning exempt income and investment/advance/loans”. 4. I have given my thoughtful consideration to the assessee’s instant sole substantive ... Revenue’s vehement contentions. I am of the considered view that once the impugned issue of unexplained investment nowhere formed subject matter of “limited” scrutiny exercise herein, both the learned lower authorities could not have added it in light of PCIT Vs. Weilburger Coatings India Pvt. Ltd. (2023) 155 taxmann.com

Saroj Kumar Dash, Debagarh vs. Income Tax Officer, Ward-2(1), Sambalpur

In the result, both the appeals of the assessee are allowed

ITA 151/CTK/2025[2017-18]Status: DisposedITAT Cuttack22 Sept 2025AY 2017-18

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.141/Ctk/2025 आयकर अपील सं/Ita No.151/Ctk/2025 (निर्धारण वर्ा / Assessment Year : 2017-2018) Saroj Kumar Dash Vs Ito, Ward-2(1), Sambalpur Guru Sahi, Deogarh Road, Debgarh 768108 Pan No. : Agjpd 7675 H (अपीलधर्थी /Appellant) (प्रत्यर्थी / Respondent) .. निर्धाररती की ओर से /Assessee By : Shri P.K.Mishra, Advocate रधजस्व की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 22/09/2025 घोषणा की तारीख/Date Of Pronouncement : 22/09/2025

For Appellant: Shri P.K.Mishra, AdvocateFor Respondent: Shri Vijay Singh, Sr. DR
Section 263Section 271A

assessee are admitted for hearing. 3. It was submitted by the ld. AR that the assessment of the assessee was selected for limited scrutiny in regard to large cash deposited in the bank account during the year. It was the submission that the said issue was examined ... been recorded in the books of accounts. It was the submission that this was not an issue which is a part of limited scrutiny nor was it an issue connected with the limited scrutiny and no approval from the concerned Pr.CIT had been taken. It was the submission that

Saroj Kumar Dash, Deogarh vs. The Income Tax Officer Ward-2(1), Sambalpur

In the result, both the appeals of the assessee are allowed

ITA 141/CTK/2025[2017-18]Status: DisposedITAT Cuttack22 Sept 2025AY 2017-18

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.141/Ctk/2025 आयकर अपील सं/Ita No.151/Ctk/2025 (निर्धारण वर्ा / Assessment Year : 2017-2018) Saroj Kumar Dash Vs Ito, Ward-2(1), Sambalpur Guru Sahi, Deogarh Road, Debgarh 768108 Pan No. : Agjpd 7675 H (अपीलधर्थी /Appellant) (प्रत्यर्थी / Respondent) .. निर्धाररती की ओर से /Assessee By : Shri P.K.Mishra, Advocate रधजस्व की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 22/09/2025 घोषणा की तारीख/Date Of Pronouncement : 22/09/2025

For Appellant: Shri P.K.Mishra, AdvocateFor Respondent: Shri Vijay Singh, Sr. DR
Section 263Section 271A

assessee are admitted for hearing. 3. It was submitted by the ld. AR that the assessment of the assessee was selected for limited scrutiny in regard to large cash deposited in the bank account during the year. It was the submission that the said issue was examined ... been recorded in the books of accounts. It was the submission that this was not an issue which is a part of limited scrutiny nor was it an issue connected with the limited scrutiny and no approval from the concerned Pr.CIT had been taken. It was the submission that

Rahul Arunkumar Pandit, Pune vs. DCIT, Circle 3, Pune

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

ITA 1926/PUN/2025[2017-18]Status: DisposedITAT Pune22 Sept 2025AY 2017-18

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1926/Pun/2025 िनधा"रण वष" / Assessment Year : 2017-18 Rahul Arunkumar Pandit, Vs. Dcit, Circle-3, Pune. Flat No.-5, Gopadma No.39, Plot No.18, Prabhat Road, Lane No.9, Pune- 411004. Pan : Abypp1142R Appellant Respondent Assessee By : None Revenue By : Shri Manishkumar Sinha Date Of Hearing : 18.09.2025 Date Of Pronouncement : 22.09.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 17.06.2025 Passed By Ld. Addl./Jcit(A)-1, Kolkata [‘Ld. Cit(A)’] For The Assessment Year 2017-18. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1] The Ld. Jcit(A) Has Erred In Confirming The Assessed Income Of The Appellant At Rs. 55,36,400/-. The Additions Made Without Considering The Fact Of The Case Are Illegal & Unsustainable In Law & The Same May Please Be Deleted. 2] The Ld. Jcit(A) Has Erred In Dismissing The Case Ex-Parte Without Waiting For Appellant To Furnish The Submission & Evidences. The Ld. Jcit(A) Ought To Have Appreciated That The Appellant Could Not Respond To The Notices, As He Has Changed His

For Appellant: NoneFor Respondent: Shri Manishkumar Sinha
Section 143(3)Section 57

also in receipt of income from house property and income from other sources i.e. interest from the parties. The case was selected for limited scrutiny under CASS for the reason of large deduction claimed u/s 57 of the IT Act. During the year under consideration, the assessee has 3 claimed

Devendra Kumar, Bijnor vs. ITO Ward (3)(5), Najibabad

Appeal is allowed

ITA 4778/DEL/2025[2017-18]Status: DisposedITAT Delhi22 Sept 2025AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 4778/Del/2025 : Asstt. Year : 2017-18 Devendra Kumar, Vs Income Tax Officer, Village Sarkara Chakrajmal, Ward-(3)(5), Dhampur, Bijnor, U.P.-246761 Income Tax Officer, Najibabad, U.P.-246731 (Appellant) (Respondent) Pan No. Bpppk0759H Assessee By: Sh. Pankaj Goel, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 22.09.2025 Date Of Pronouncement: 22.09.2025 Order This Assessee’S Appeal For Assessment Year 2017-18, Arises Against The Addl./Jcit(A)-1, Ahmedabad’S Din & Order No.Itba/Apl/S/250/2024-25/1069778857(1) Dated 18.10.2024, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Pankaj Goel, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 143(2)Section 143(3)Section 44A

framed on 25.12.2019 and upheld in the lower appellate proceedings, it emerges at the outset that it was a case of 2 Devendra Kumar “limited” scrutiny to examine his cash deposits only which ended in estimation of his profits in issue. 4. I have given my thoughtful consideration ... Revenue’s vehement contentions. I am of the considered view that once the impugned issue of presumptive business income nowhere formed subject matter of “limited” scrutiny exercise herein, both the learned lower authorities could not have added it in light of PCIT Vs. Weilburger Coatings India

Krishana Shanwal, Hisar vs. Deputy Commissioner of Income Tax, Hisar Circle, Hisar

In the result, the appeal of the assessee is allowed

ITA 410/DEL/2025[2017-18]Status: DisposedITAT Delhi22 Sept 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahmankrishana Shanwal, Vs. Dcit, Hisar Circle, House No.155, Sector 15A, Hisar. Hisar – 125 001 (Haryana). (Pan : Btops9929Q) (Appellant) (Respondent) Assessee By : Shri Kuldip Khera, Ca Revenue By : Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing : 30.06.2025 Date Of Order : 30.06.2025 O R D E R Per S.Rifaur Rahman,Am: 1. This Appeal Has Been Filed By The Assessee Against The Order Of Ld. Addl./Jcit (A), Agra [“Ld. Jcit(A)”, For Short] Dated 30.12.2024 For The Assessment Year 2017-18. 2. Brief Facts Of The Case Are, Assessee Filed Its Return Of Income On 21.08.2017 Declaring An Income Of Rs.52,49,050/- For The Ay 2017-18. The Return Was Processed Under Section 143(1) Of The Income-Tax Act, 1961 (For Short ‘The Act’). The Case Was Selected For Limited Scrutiny Under Cass For The Following Issues :-

For Appellant: Shri Kuldip Khera, CAFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 143(1)Section 143(2)Section 143(3)Section 154Section 270ASection 56Section 57Section 89Section 89(1)

return was processed under section 143(1) of the Income-tax Act, 1961 (for short ‘the Act’). The case was selected for limited scrutiny under CASS for the following issues :- 2 The assessee has claimed substantial relief u/s 89. (ii) Salary income shown in ITR is less than the salary