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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Naman Hemantbhai Shah, Ahmedabad vs. The ITO, Ward-5(3)(2), Ahmedabad

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

ITA 531/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2017-18

Section 143(3)Section 234Section 69A

filed return of income for the A.Y. 2017-18 on 29.03.2018 declaring total income of Rs.3,74,880/-. The case was selected for limited scrutiny to examine the Naman Hemantbhai Shah vs. ITO Page 2 of 5 cash deposits made during demonetisation period. The Assessing Officer found that the assessee

Narayanbhai Shivabhai Patel, Mehsana vs. The ITO, Ward-1, Mehsana

In the result, the appeal of the assessee is allowed

ITA 1357/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2020-21

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2020-21

Section 143(3)Section 270ASection 270A(6)Section 270A(6)(a)Section 270A(6)(b)Section 56(2)(x)

income for the A.Y. 2020-21 on 13.02.2021 declaring total income of Rs.13,89,890/-. The case of the assessee was selected for limited scrutiny to examine the purchase value of property which was less than the value as per the stamp authority. It transpired that the assessee

Thane Zilla Vidyasevak Sahakari Patpedhi Ltd, Mumbai vs. ITO, Ward 3(4), Mumbai

In the result, the appeal of the assessee is allowed

ITA 4900/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Sept 2025AY 2018-19

Bench: Ms. Kavitha Rajagopal & Smt. Renu Jauhrithane Zilla Vidyasevak Vs. Commissioner Of Income Sahakari Patpedhi Ltd. Tax (Appeals), National Through Mr. Sudhir Evram Faceless Appeal Centre/ Ghagas Chairman 1St Floor, Ward 3(4) Sundera Plaza, Near Sanai Ashar It Park, Neheru Mangal Hall, Kalyan (West), Nagar, Wagle Industrial Kalyan-421301. Estate, Thane West, Thane- 400604. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadft4365L Appellant .. Respondent

For Appellant: Shri Shekhar Parwardhan, CAFor Respondent: Shri Hemanshu Joshi, Sr. DR

Section 143(3)Section 250Section 80P(2)(a)Section 80P(2)(d)

Maharashtra Co-operative Societies Act 1960. It filed its return declaring Nil income on 30.10.2018 for A.Y. 2018-19. The case was selected for limited scrutiny. Ld. AO observed that the assessee had earned interest income of Rs. 1,06,40,175/- on its deposits. Out of this

Saurashtra Cement Limited (Erstwhile M/S. Villa Trading Company Private Limited), Bachbay Reclamation vs. DCIT 1(3)(2), Mumbai, Maharishi Karve Road

In the result, the appeal of the assessee is allowed

ITA 2481/MUM/2025[2016-2017]Status: DisposedITAT Mumbai18 Sept 2025AY 2016-2017

Bench: Ms Suchitra Kamble & Shri Girish Agrawalm/S. Saurashtra Cement Limited The Deputy Commissioner Vs. (Erstwhile M/S. Villa Trading Of Income Tax, Company Private Limited), 1(3)(2), 4Th Floor, Nk Mehta Mumbai. International House, Babubhai Chinai Marg, 178 Bachbay Reclamation, Mumbai-400020. [Pan :Aaacv5221 F] (Appellant) .. (Respondent) Appellant By : Shri Devendra Jain, Ar Respondent By: Shri Bhagirath Ramawat, Sr. Dr Date Of Hearing 15.09.2025 Date Of Pronouncement 18.09.2025 O R D E R Per Suchitra Kamble:

For Appellant: Shri Devendra Jain, ARFor Respondent: Shri Bhagirath Ramawat, Sr. DR

Section 115JSection 142(1)Section 143(2)Section 14A

normal provision of the Act and at Rs.(-)102,03,583/- u/s.115JB of the Act. The case of the assesse was selected for limited scrutiny on the following issues: a. whether tax aspects related to investments/advances/loans have been considered in the return of income. b. Whether deduction claimed on account

Ashutosh Shah, Patna vs. Deputy Commissioner, Circle -4, Patna

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

ITA 619/PAT/2024[2017-18]Status: DisposedITAT Patna17 Sept 2025AY 2017-18

Bench: This Bench. In This Connection, The Assessee Has Filed A Petition Explaining The Reasons For Such Delay. Upon Considering

Section 143(3)Section 250Section 69A

that the assessee filed return of income for the year under consideration declaring income of ₹10,36,550/-. The case was selected for limited scrutiny for verifying large cash deposits during the demonetisation period. The Assessing Officer completed the assessment under section 143(3) of the Income

J.K.V. Stonex, Kishangarh vs. Income Tax Officer, Kishangarh

In the result, the appeal of the assessee is allowed

ITA 542/JPR/2025[2012-13]Status: DisposedITAT Jaipur17 Sept 2025AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: ShriSandeep Jhanwar, CAFor Respondent: Shri Gaurav Awasthi, JCIT-DR

Section 147Section 68

assessee firm had not filed return of income u/s 139(1) of the IT Act, 1961. 2. The case of assesse was selected for limited scrutiny for AY 2016-17 to examine source of capital contribution by partners in assesse firm. It was noticed by ld. AO that assessee firm

Rahul Bhowmick (Legal Heir of Fullara Bhowmick, Deceased), Burdwan vs. ITO, Ward 1(1), Burdwan

In the result, appeal of the assessee is allowed

ITA 701/KOL/2025[2017-18]Status: DisposedITAT Kolkata17 Sept 2025AY 2017-18

Bench: Shri & Rajesh Kumarassessment Year : 2017-18 Rahul Bhowmick (Legal Heir Of Vs. Income Tax Officer, Ward 1(1), Fullara Bjhowmick Deceased), Burdwan S/O. Ratan Bhjowmick, Perbirhata, G Troad, Sripally, Burdwan-713013 Pan/Gir No.Afnpb 0338 L (Appellant) .. ( Respondent) Assessee By : Shri Amit Agrawal, Adv Revenue By : Shri Shankar Naskar, Sr Dr

For Appellant: Shri Amit Agrawal, AdvFor Respondent: Shri Shankar Naskar, Sr DR

Section 133(6)Section 68

business of grocery items. The case of the assessee was selected for P a g e 1 | 4 Assessment Year : 2017-18 limited scrutiny for huge cash deposits in the bank account of the assessee. Accordingly, statutory notices were issued and served upon the assessee. The Assessing Officer called

Deputy CIT, Central Circle-6, Income Tax Department vs. Santosh Hospitals Private Limited, No

ITA 1534/DEL/2024[2015-16]Status: DisposedITAT Delhi17 Sept 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 115JSection 147Section 148Section 148ASection 36(1)(va)Section 37Section 40Section 68

Rs.48,93,564/- under normal provisions of the Act and book profits u/s 115JB at Rs.88,55,247/-. The assessment was completed under limited scrutiny through CASS vide order dated 29.09.2017 accepting the loss/income declared by the assessee. Subsequently notice u/s 148 dated 31.03.2021 was issued for reopening the assessment

Udita Gupta, Delhi vs. ACIT Central Circle-29, New Delhi

In the result, appeal filed by the assessee is allowed

ITA 2017/DEL/2019[2014-15]Status: DisposedITAT Delhi17 Sept 2025AY 2014-15

Bench: SHRI ANUBHAV SHARMA (Judicial Member), SHRI KRINWANT SAHAY (Accountant Member)

Section 143(2)Section 143(3)Section 250Section 68

Heard and perused the record. Brief facts of the case are that the case of the assesse was picked up for limited scrutiny and during the assessment proceedings, the assessee’s claim of earning capital gain amounting to Rs.1,11,03,437/- from sale of shares of M/s Trinty Tradelink ... despite the fact that the Ld. AO has travelled beyond the scope of notice u/s 143(2) asthis is a LIMITED SCRUTINY matter. 3. That on facts and in circumstances of the case and in law, Ld. CIT(A) erred in sustaining the addition of Rs.1,19,89,937/- under

Murli Dhar Upadhyay, Jaipur vs. ITO Ward 6(3), Jpr, Jaipur

In the result, stands allowed

ITA 252/JPR/2025[2017-18]Status: DisposedITAT Jaipur16 Sept 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Ashok Kumar Gupta, AdvFor Respondent: Shri Gautam Singh Choudhary, JCIT a

Section 143(2)Section 143(3)Section 270A(1)Section 40A(3)

CASS for examination of cash deposited during the demonetization period. Notice issued u/s 143(2) does not specify whether it has been selected for Limited scrutiny or Complete scrutiny. During the hearings, the Ld. AR submitted that it was a case of Limited scrutiny. He also referred to the notices ... Coordinate Bench of ITAT Bangalore in the case of H.N. Ravindra vs. ITO, in ITA No.1065/Bang/2019 held that the case was selected for limited scrutiny with respect to cash deposits in bank account during demonetization period (9th Nov. to 30th Dec); disallowance u/s 43B for non-payment

Mr. Avinash Haribhau Shinde, Pune vs. ITO, Ward 14(1), Pune

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

ITA 1657/PUN/2025[2017-18]Status: DisposedITAT Pune16 Sept 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Abhay AvchatFor Respondent: Shri Harshit Bari

Section 143(2)Section 144Section 250

income of Rs.1,32,310/- declared in the e- return for A.Y. 2017-18 furnished on 18.03.2018. After the case being selected for Limited Scrutiny under CASS to verify the cash deposit during the demonetization period, ld. Assessing Officer (AO) issued valid notices u/s.143

Smt Bertha D'Costa, Cavelossim, Goa vs. Income Tax Officer, Ward -2, Margao

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

ITA 159/PAN/2019[2015-16]Status: DisposedITAT Panaji15 Sept 2025AY 2015-16

Bench: Shri Pavan Kumar Gadalei T A. Nos.158 &159/Pan/2019 (A.Y. 2015-16 ) Shri.Julio D Costa, Vs Ito-Ward-2, H.No.337,Mobor,Cavelossim, Blessings Pioneer Salcete,Goa-403731. Complex, (Pan:Aewpd6709F) Old Market, Margoa-403601,Goa. Smt.Bertha D Costa, Ito-Ward-2, Vs H.No.337,Mobor,Cavelossim, Blessings Pioneer Salcete,Goa-403731. . Complex, (Pan:Aewpd6748N) Old Market, Margoa-403601,Goa. (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Shrinivas Nayak.Ar Revenue By Smt.Manju Thakur.Sr.Dr सुनवाई की तारीख/Date Of Hearing 09.09.2025 घोषणा की तारीख/Date Of Pronouncement 15.09.2025 Order Per Pavan Kumar Gadale, Jm: These Two Appeals Are Filed By The Assesses (Husband & Wife) Against The Separate Orders Of The Cit(A) -1 Panaji Passed U/Sec143(3) & U/Sec 250 Of The Act. The Assesses Are Governed By The Portuguese Civil Code & Provisions Of Section 5A Of The Act. 2. Since The Issues Involved In These Two Appeals Are Common & Identical, Hence They Are Clubbed, Heard & Aconsolidated Order Is Passed. For The Sake Of Convenience

Section 44ASection 5A

return of income for the A.Y 2015-16 on 06.07.2016 disclosing a total income of Rs.2,78,520/-.Subsequently the case was selected for limited scrutiny under the CASS and the Assessing Officer (A.O) has issued notice u/sec 143(2) and u/se 142(1) of the Act. In compliance

Shri Julio D'Costa, Cavelosim, Goa vs. Income Tax Officer, Ward -2, Margao

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

ITA 158/PAN/2019[2015-16]Status: DisposedITAT Panaji15 Sept 2025AY 2015-16

Section 44ASection 5A

Anju Sanghi, Jaipur vs. ACIT, Circle -4, Jaipur

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

ITA 769/JPR/2025[2017-18]Status: DisposedITAT Jaipur15 Sept 2025AY 2017-18

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyalanju Sanghi, 31, Meghdhan Complex Ambabari, Jaipur 302 023 Pan No.: Amtps 3732L ...... Appellant

For Appellant: Mr. Uma Shankar Sharda, CA. Ld. ARFor Respondent: Mr. Gaurav Awasthy, JCIT, Ld. DR

Section 115BSection 131Section 250Section 54FSection 69A

assessee filed her return of income on 31.10.2017 declaring total income at Rs. 52,34,970/-. The case of the assessee was selected for Limited Scrutiny under CASS. The assessee is proprietor of M/s. Sanghi Steel and partner in M/s. P.K. Industries and M/s. Auto Plux AV. The case

Rajasthan Ophthalmological Society, Jaipur vs. ITO, Jaipur

In the result, the appeal of the assessee is allowed

ITA 582/JPR/2025[2018-19]Status: DisposedITAT Jaipur15 Sept 2025AY 2018-19

Bench: DR. M.L. MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Hemang Gargieya, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR a

Section 11(2)Section 11(5)Section 12ASection 139(1)Section 143(3)Section 234A

declaring NIL income, and a revised return on 26.10.2018, also at NIL income. The return was processed, and the case was selected for limited scrutiny under CASS for the issue of “accumulation of income by trust.” 4. During the assessment proceedings, the appellant submitted that

Pradeep Kumar Rochwani, Jodhpur vs. Circle (Intl Tax), Jaipur

In the result, appeal of the assessee is allowed

ITA 567/JPR/2025[2018-19]Status: DisposedITAT Jaipur15 Sept 2025AY 2018-19

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Rajendra Jain, Adv. (throughFor Respondent: Shri Rajesh Ojha, CIT-DR a

Section 143(3)Section 144C(1)Section 263

section 143(1) of the Income Tax Act, 1961 on 16.11.2019 by central processing cell. Subsequently, the case of the assessee was selected for limited scrutiny 5 Pradeep Kumar Rochwani, Jodhpur. through CASS. Notice generated under section 143(2) of IT Act, 1961 through system was sent to the assessee ... this appeal. While passing the impugned order ld. PCIT has not appreciated the fact that the case of the assessee was selected for limited scrutiny to examine the claim of large refund. Wherein the based on the scope ld. AO had already examined and verified the cost of acquisition including

Baba Hi-Tech Pvt. Ltd., Kolkata vs. ACIT, Central Circle 4(4), Kolkata

In the result, the appeal of the assessee is allowed

ITA 798/KOL/2025[2021-2022]Status: DisposedITAT Kolkata15 Sept 2025AY 2021-2022

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Asst. Commissioner Of Income Baba Hi-Tech Pvt. Ltd. Tax, Circle 4(4) Room No.5, 3 Rd Floor, Aaykar Bhawan Poorva, 11/A, M.D. Road, Vs. 110, Shantiapply, Em Byepass Kolkata-700007 Kolkata-700107, West Bengal (Respondent) (Appellant) Pan No. Aakcs6228D Assessee By : Shri Saurabh Gupta, Ar Revenue By : Shri Sanjib Kumar Paul, Dr Date Of Hearing: 04.09.2025 Date Of Pronouncement: 15.09.2025

For Appellant: Shri Saurabh Gupta, ARFor Respondent: Shri Sanjib Kumar Paul, DR

Section 143(2)Section 143(3)

vehemently submitted that the notice u/s 143(2) of the Act dated 27.06.2022, 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

Rohit Seth, Kolkata vs. ITO, Ward 30(4), Kolkata

In the result, the appeal of the is allowed

ITA 1205/KOL/2025[2017-2018]Status: DisposedITAT Kolkata15 Sept 2025AY 2017-2018

Bench: Shri Rajesh Kumar, Am Ito, Ward 30(4), Rohit Seth Aaykar Bhawan Dakshin, Fd 100, Sector-3, 2, Gariahat Road South, Salt Lake City, Kolkata-700106 Vs. Kolkata-700068 West Bengal West Bengal (Appellant) (Respondent) Pan No. Dfvps7680F Assessee By : Shri Manish Tiwari, Ar Revenue By : Shri Abhijit Adhikari, Dr Date Of Hearing: 10.09.2025 Date Of Pronouncement: 15.09.2025

For Appellant: Shri Manish Tiwari, ARFor Respondent: Shri Abhijit Adhikari, DR

Section 143(2)

vehemently submitted that the notice u/s 143(2) of the Act dated 24.09.2018, does not specify whether it is a limited scrutiny or a complete scrutiny or a compulsory manual scrutiny. The ld. AR submitted that the CBDT has issued specific instruction vide Rohit Seth; A.Y. 2017-18 instruction

Sri. Appanna Devarao Sirdeshpande, Bengaluru vs. ACIT, Circle-2(1)(1), Bangalore

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

ITA 597/BANG/2025[2020-21]Status: DisposedITAT Bangalore15 Sept 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2020-21

For Appellant: Shri Chaitanya V. Mudrabettu, AdvocateFor Respondent: Shri Ganesh R. Ghale, Advocate –Standing

Section 143(2)Section 250

declaring a total income of Rs. 5,19,510/-. Subsequently, the case of the assessee was selected for limited scrutiny under CASS for the reason of “Agricultural Income” and accordingly notices u/s. 143(2) and 142(1) of the Act were Sri Appanna Devarao Sirdeshpande Page 3 of 6 issued ... rival submissions and perused the material available on record. It is an undisputed fact that the case of the assessee was selected for limited scrutiny under CASS for the reason of “Agriculture Income”. During the course of assessment proceedings, the assessee submitted that well-grown 25- mango trees, 58- teak

Sumatinath Builders, Nallasopara vs. ACIT, Circle 4, Thane

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

ITA 4685/MUM/2025[2015-16]Status: DisposedITAT Mumbai15 Sept 2025AY 2015-16

Bench: Shri Om Prakash Kantms Suchitra Kamblesumatinath Builders, Vs. The Assistant Commissioner Shop No.1, Of Income Tax, Jay Vijay Nagari-1, Circle-4, Virar Link Road, Thane. Nallasopara, Vasai-Virar Dist. Thane-401209. Maharashtra. [Pan :Abdfs6440 E] (Appellant) .. (Respondent) Appellant By : None Respondent By: Ms Kavitha Kaushik, Sr. Dr Date Of Hearing 09.09.2025 Date Of Pronouncement 15.09.2025 O R D E R Per Suchitra Kamble:

For Appellant: NoneFor Respondent: Ms Kavitha Kaushik, Sr. DR

Section 133ASection 139(1)Section 143(2)Section 271(1)(c)Section 43CSection 68

Assessment Year 2015-16, thereby declaring total income at Rs. 3,11,14,710/-. The assessee’s case was selected for limited scrutiny to verify high increase in sundry creditors as compared to preceding year, high interest expenses as compared to business turnover, mismatch in sales turnover reported in Audit