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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Nadarajan Kalyani, Tiruchengode vs. ACIT, Circle-1, Erode

In the result, appeal filed by the assessee is allowed

ITA 2898/CHNY/2025[2016-17]Status: DisposedITAT Chennai04 Mar 2026AY 2016-17

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

Section 144Section 69Section 69A

that the assessee filed return of income (RoI) on 01.02.2017 declaring total income at ₹10,78,323/-. Later, the case was selected for limited scrutiny through CASS for the reason “high cash on hand shown in balance-sheet as compared to preceding year and RoI filed after 07.11.2016, whether

Ramakkonar Balakrishnan, Madurai vs. PCIT, Madurai

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

ITA 2006/CHNY/2025[2017-18]Status: DisposedITAT Chennai04 Mar 2026AY 2017-18

Bench: Shri Aby T Varkey & Shri S.R. Raghunatha

For Appellant: Mr. Bipin C.N, CITFor Respondent: 21.01.2026
Section 143(3)Section 263Section 69A

filed his return of income on 25.05.2017 for the AY 2017-18, declaring total income of Rs.3,11,630/-. The case was selected for limited scrutiny under CASS to verify “Cash deposit during the year” and the Assessing Officer issued statutory notices to the assessee. In response, the assessee submitted

M/S. Dinesh Textile Mills, Tiruppur vs. DCIT, Circle-1, Tiruppur

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

ITA 3062/CHNY/2025[2018-19]Status: DisposedITAT Chennai03 Mar 2026AY 2018-19

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita No.3062/Chny/2025 िनधा#रण वष# /Assessment Year: 2018-19

For Appellant: Mr. Suraj Nahar, C.A ()For Respondent: Ms. R. Anitha, Addl. CIT
Section 143(3)Section 250Section 40

return of income for A.Y 2018-19 on 29.10.2018 declaring total income of Rs. 2,13,90,090/-. The case was selected for limited scrutiny to verify the issue of compliance with the TDS provisions on payments outside India. The A.O completed the assessment

Hotel Maleekara Pattina Souharda Sahakaari Sangha Niyamitha, Tumkur vs. Income Tax Officer, Ward-1 & Tps, Tumkur

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

ITA 1110/BANG/2025[2017-18]Status: DisposedITAT Bangalore03 Mar 2026AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri A. Shivaram, CA
Section 142(1)Section 143(2)Section 234ASection 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

income as Nil. The assessee had claimed the entire income as deduction u/s. 80P of the Act. The said return was selected for limited scrutiny for verifying the deduction claimed under Chapter VIA. Notice u/s. 143(2) was issued and subsequently notices u/s. 142(1) were issued calling

Shri K.P. Magennavar Laxmi Credit Souharda Sahakari Sangh Ltd.Manjari., Chikodi vs. Income Tax Officer, Ward-1, Nippani

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

ITA 33/PAN/2026[2015-2016]Status: DisposedITAT Panaji27 Feb 2026AY 2015-2016

Bench: Shri Pavan Kumar Gadalei T A. No.33/Pan/2026 (A.Y. 2015-16 ) Shri K.P.Magennavar Laxmi Vs I.T.O-Ward-1, Credit Souharda Sahakari Nemchand Building, . Sangh Limited, 747,Ashoknagar, 521,Laxmibuilding,Mainroad, Nipani-591237, Manjari, Chikodi, Karnataka. Belagavi-591213, Karnataka. Pan .No. Aabas3175N (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Jaykumar Patil.Ar Revenue By Smt.Thamba Mahendra.Sr.Dr सुनवाई की तारीख/Date Of Hearing 25.02.2026 घोषणा की तारीख/Date Of Pronouncement 27.02.2026 Order Per Pavan Kumar Gadale, Jm: The Assessee Has Filed The Appeal Against The Order Of Addl/Jcit(A)-7 Mumbai Passed U/Se 143(3) & U/Sec250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Denial Of Claim Of Deduction U/Sec80P(2)(A)(I) Of The Ac & Without Prejudice Alternate Relief U/Sec80P(2)(D) Of The Act On Interest Income From Cooperative Banks & Scheduled Banks. 2. The Brief Facts Of The Case Are That, The Assessee Souhard Credit Cooperative Society Is Engaged In Providing

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

disclosing a total income of Rs.NIL/- after claiming deduction u/sec80P(2)(a)(i) of the Act and the case was selected for limited scrutiny under the CASS. Subsequently the Assessing Officer (A.O) has issued notice u/sec143 (2) and u/sec 142(1) of the Act calling for the details

Shahanshah Dal Mill, Bhopal vs. ITO-5(3), Bhopal

Appeal is dismissed

ITA 335/IND/2025[2015-16]Status: DisposedITAT Indore27 Feb 2026AY 2015-16

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 143(2)Section 147Section 40A(2)(b)

under consideration, the assessee filed return declaring a total income of Rs. 30,690/-. The case of assessee was selected for limited scrutiny to examine the payments made to related persons u/s 40A(2)(b) and claim of high interest expenditure. The AO issued notices u/s 143(2)/142

Varadhan Sureshbabu, Chennai vs. ACIT, Non Corporate Circle-7(1), Chennai

The appeal of the assessee is allowed for statistical purposes

ITA 3696/CHNY/2025[2017-18]Status: DisposedITAT Chennai27 Feb 2026AY 2017-18

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3696/Chny/2025 िनधा$रण वष$ /Assessment Year: 2017-18

For Appellant: NoneFor Respondent: Dr. M.D.Vijay Kumar, JCIT
Section 250Section 54Section 54F

filed the return of income for AY 2017-18 on 08.05.2017 declaring total income of Rs.23,58,080/-. The case was selected for limited scrutiny and the statutory notices were duly served on the assessee. The assessee during the year under consideration has sold along Varadhan Sureshbabu :- 2 -: with

Bhavin Mahendra Khatri, C-30, Ambaji Apartment Priyamohan Chs, Devidayalc vs. Income Tax Officer, Kautiliya Bhavan

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

ITA 7247/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Feb 2026AY 2015-16

Bench: Shri Om Prakash Kant () And

Section 133(6)

assessee filed his return of income on 28th March 2016, declaring a total income of %10,55,750/-. The case was subsequently selected for limited scrutiny. During the scrutiny proceedings, the Assessing Officer noted that as per Form No. 26AS, he assessee received Rs.79,28,938/- from M/s Brooks Brothers

Rachna Dipesh Laddha, Vadodara vs. Income Tax Officer, Ward 1(3)(2) Vadodara Gujarat, Vadodara

In the result, the appeal of the assessee is dismissed

ITA 1922/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: NoneFor Respondent: Shri Rignesh Das, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 69A

alleged unexplained cash deposits under section 69A of the I. T act 1961 despite the fact that cash deposits was outside the scope of Limited Scrutiny under CASS for A.Y. 2017-18. 2. On the facts and circumstances of the case as well as in law on the subject

Arbind Ray, Kolkata vs. D.C.I.T., Circle - 40, Kolkata

In the result, the appeal of the assessee is allowed

ITA 2321/KOL/2025[2321]Status: DisposedITAT Kolkata26 Feb 2026

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Arbind Ray Dcit, Circle-40 1, Arbinda Pally, Jinjira Bazar, 3, Govt. Place (West) Brace Bridge, S.O. Kolkata, Vs. Kolkata-700001, West Bengal Kolkata-700007, West Bengal (Appellant) (Respondent) Pan No. Aqipr9775R Assessee By : Shri Anup Sinha, Ar Revenue By : Shri Dheeraj, Dr Date Of Hearing: 09.02.2026 Date Of Pronouncement: 26.02.2026

For Appellant: Shri Anup Sinha, ARFor Respondent: Shri Dheeraj, DR
Section 133(6)Section 143(3)Section 68Section 69C

case of the assessee was selected for scrutiny through Computer Assisted Scrutiny Arbind Ray; A.Y. 2016-17 Selection (CASS) under limited scrutiny and accordingly statutory notices along with questionnaire were issued and served upon the assessee. In response to the said notices, the assessee filed all the details before

Bobst Bielefeld Gmbh, Germany vs. The Assistant Commissioner of Income Tax Int Tax Circle 1(3)(1), Mumbai

ITA 6030/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Feb 2026AY 2018-19

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Siddesh ChauguleFor Respondent: Shri Krishna Kumar, Sr.DR
Section 234Section 234ASection 270A

after claiming credit for TDS amounting to Rs 12,65,943, final tax liability was determined at Nil. 4. The return was selected for limited scrutiny under Computer Assisted Scrutiny Selection (CASS) for examination of double taxation relief claimed u/s. 90/91 of the Act. Notices ... ADIT [2008] 23 SOT 29 (Kolkata) (URO) 8. Per contra, the Ld. CIT-DR submitted that the case of the assessee was selected for limited scrutiny to examine double taxation relief u/s 90/91 claimed by the assessee in its return of income and, therefore, the AO was prevented to examine

Bobst Bielefeld Gmbh, Germany vs. The Assistant Commissioner of Income Tax Int Tax Circle 1(3)(1), Mumbai

ITA 6029/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Siddesh ChauguleFor Respondent: Shri Krishna Kumar, Sr.DR
Section 234Section 234ASection 270A

after claiming credit for TDS amounting to Rs 12,65,943, final tax liability was determined at Nil. 4. The return was selected for limited scrutiny under Computer Assisted Scrutiny Selection (CASS) for examination of double taxation relief claimed u/s. 90/91 of the Act. Notices ... ADIT [2008] 23 SOT 29 (Kolkata) (URO) 8. Per contra, the Ld. CIT-DR submitted that the case of the assessee was selected for limited scrutiny to examine double taxation relief u/s 90/91 claimed by the assessee in its return of income and, therefore, the AO was prevented to examine

Ramanbhai Shivabhai Parmar, Mahisagar vs. The ITO, Ward-1, Lunawada

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

ITA 640/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2017-18

Bench: Ms. Suchitra Kambleassessment Year 2017-18

For Appellant: Shri Divyang Shah, A.RFor Respondent: Ms. Ketaki Desai, Sr. D.R
Section 143(2)Section 250Section 69A

assessee filed return of income on 16-01-2018 declaring total income of Rs. 25,640/-. The case of the assessee was selected for limited scrutiny. Despite giving statutory notices, the assessee did not file written submission. But on 14- 11-2019, the assessee filed reply. The Assessing Officer after

Mamta Construction Co, Mehsana vs. Deputy Commissioner of Income Tax, Gandhinagar

In the result, the appeal of the assessee is allowed

ITA 1530/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalmamta Construction Co., Deputy Commissioner Vs. 20, Madhuvan Complex, Of Income-Tax, Nr. Icici Bank, State Highway, Gandhinagar Mehsana-384 002 [Pan :Aaifm 6254 A] (Appellant) .. (Respondent) Appellant By : Shri Hasmukh V. Doshi, Ca Respondent By: Shri Kamal Deep Singh, Sr. Dr Date Of Hearing 10.12.2025 Date Of Pronouncement 25.02.2026

For Appellant: Shri Hasmukh V. Doshi, CAFor Respondent: Shri Kamal Deep Singh, Sr. DR
Section 142(1)Section 250

also it will be injustice to us if order is passed same as draft order. Further, our case was selected for limited scrutiny only with the reason of "Contract receipt of fees" but issues covered under draft order is other than the reason of selection of the assessment. The issues

Repro India Limited, Lower Parel, Mumbai vs. Commissioner of Income Tax (Appeals), Mumbai

The appeal of the assessee is partly allowed

ITA 6698/MUM/2025[2018-19]Status: DisposedITAT Mumbai25 Feb 2026AY 2018-19

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

Section 143(3)Section 144BSection 250

reporting current year losses to be carried forward amounting to Rs. 10,68,34,325/-. The case was selected for limited scrutiny under the E- Assessment Scheme, 2019. The Assessing Officer completed assessment by making addition of Rs. 35,79,78,081/-. 3. Before the CIT(A), the assessee challenged

City Holdings Private Limited (Erstwhile City Holdings Limited), Kolkata vs. ACIT, Circle 3(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2683/KOL/2025[2017-2018]Status: DisposedITAT Kolkata24 Feb 2026AY 2017-2018

Bench: Shri Rajesh Kumar (Accountant Member), Shri Pradip Kumar Choubey (Judicial Member)

Section 10(33)Section 14ASection 250

return of income for assessment year 2017-18 by declaring an income of Rs.9,83,61,241/-. The case of the assessee selected under limited scrutiny for the reason that Expenses debited to Profit and loss account for earning exempt income is significantly lower as compared to investment made

Bihari Parmanand Kandhari, Mumbai vs. Aci, Circle -23(1), Mumbai

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

ITA 7925/MUM/2025[2018-19]Status: DisposedITAT Mumbai23 Feb 2026AY 2018-19

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2018-19

For Respondent: Mr. Akshay Jain
Section 56(2)

failed to appreciate that the Ld. AO has travelled beyond his Bihari Parmanand Kandhari Bihari Parmanand Kandhari was not the part of limited scrutiny. was not the part of limited scrutiny. 2. That on the facts and circumstances of the case and law, the Ld. 2. That on the facts

Sandeep Vishnu Redekar, Belagavi vs. Income Tax Officer, Ward - 1, Gokak

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

ITA 36/PAN/2026[2017-18]Status: DisposedITAT Panaji20 Feb 2026AY 2017-18

Bench: Shri Pavan Kumar Gadalei T A. No.36/Pan/2026 (A.Y. 2017-18) Sandeep Vishnu Redekar, Vs I T O Ward(1), H.No.103,Daddi,Tal-Hukkeri, Dr Ghogeri Building, . Belgavi-591254, Belgaum Road, Karnataka. Gokak-591307, Karnataka. Pan: Amwpr8609J (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Swapnil Patil.Ar Revenue By Shri.Sanket Deshmukh.Sr.Dr सुनवाई की तारीख/Date Of Hearing 18.02.2026 घोषणा की तारीख/Date Of Pronouncement 20.02.2026 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of Addl/Jcit(A) Passed U/Sec 143(3) & U/Sec 250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Ex-Parte Order Of The Cit(A) Sustaining The Addition Of Commission & Unexplained Money U/Sec69A Of The Act Made By The Assessing Officer. 2. The Brief Facts Of The Case Are That, The Assessee Is Engaged In The Business Of Dealing With The Sale Of Prepaid Charges Of Mobile To Customers. The Assesee Has Filed The Return Of Income For A.Y.2017-2018 On 14.09.2017 Disclosing A Total Income Of Rs.2,68,990/- & The Case

A.Y.2017-2018 on 14.09.2017 disclosing a total income of Rs.2,68,990/- and the case 2 ITA. No.36/PAN/2026 Sandeep Vishnu Redekar.. was selected for limited scrutiny under the CASS and notice u/sec 143(2) and u/sec142(1) of the Act are issued.The Assessing Officer (AO) based on the information from

Rishi Ajat Shatru Nath Sahdeo, Ranchi vs. ITO Ward-2(5), Ranchi

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

ITA 127/RAN/2025[2016-17]Status: DisposedITAT Ranchi20 Feb 2026AY 2016-17

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayrishi Ajat Shatru Nath Sahdeo, I.T.O., S/O-R.B. Bhushan, Ganga Motor Ward-2(5), Vs. Compound, Hehal, Near Universal Ranchi. Honda Show Room, Hehal Tangratoli, Ranchi-834001 (Jharkhand) Pan No. Adaps 5063 N Appellant/ Assessee Respondent/ Revenue

raised following grounds of appeal: "1. For that the learned CIT(A) failed to adjudicate on the issue of selection of case for limited scrutiny while set a siding and remanding the matter to A.O. (4572511). 2. For that non adjudication of the ground of limited scrutiny by the learned ... page No. 12 of the assessment order is against the law and unjustified. 3. For that the case was selected for limited scrutiny to verify increase in share capital, without proper verification and application of mind. 4. For that other grounds shall be urged at the time of hearing

Sarda Brijgopal, Hyderabad vs. ITO, Ward-5(1), Hyderabad

ITA 1891/HYD/2025[2017-18]Status: DisposedITAT Hyderabad20 Feb 2026AY 2017-18

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1891/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) Sarda Brijgopal, Vs. Income Tax Officer, Hyderabad. Ward-5(1), Pan: Aamhs2717L Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ms. Aluru V Sai Sudha, Ca राज" व "ारा/Revenue By: Shri K. Vamsi Krishna, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 05/02/2026 घोषणा की तारीख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Additional/Joint Commissioner Of Income Tax (Appeals)-4, Chennai, Dated 30/09/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 18/12/2019 For The Assessment Year (Ay) 2017-18. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Ms. Aluru V Sai Sudha, CAFor Respondent: Shri K. Vamsi Krishna, Sr. DR
Section 143(1)Section 143(2)Section 143(3)Section 234BSection 69A

income filed by the assessee was processed under section 143(1) of the Act. Subsequently, the case of the assessee was selected for “limited scrutiny” and notice under section 143(2) of the Act was issued and duly served upon him. 3. During the course of the assessment proceedings