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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Venkateswarlu Chandu, Delhi vs. Deputy Commissioner of Income Tax, Circle - 43(1), New Delhi

In the result, the instant assessee’s appeal is allowed

ITA 3119/DEL/2025[2017-18]Status: DisposedITAT Delhi12 Sept 2025AY 2017-18

Bench: Shri Mahavir Singh, Hon’Bleasstt. Year : 2017-18 Venkateswarlu Chandu, Vs. Dcit, Cc-43(1), B-905, Best Paradise, Plot No. 4, New Delhi Bhartiya Cghs, Sector-19, Dwarka, Delhi – 110 075 (Pan: Acdpc4984A) (Appellant) (Respondent) Appellant By : Sh. Rajat Jain, Ca & Sh. Akshat Jain, Ca Respondent By : Shri Manoj Kumar, Sr. Dr. Date Of Hearing 03.09.2025 Date Of Pronouncement 12.09.2025 Order This Appeal Has Been Filed By The Assessee Against The Order Dated 24.04.2025 Passed By The Nfac, Delhi For The Assessment Year 2017-18. The Solitary Issue Raised In This Appeal Is Relating To Sustaining Of Addition Of Rs. 9,99,000/- Made By The Ao U/S. 69C Of The Act. 2. Brief Facts Of The Case Are That The Assessee E-Filed His Return Of Income For The Assessment Year 2017-18 On 31.10.2017, Declaring Total Income Of Nil. Subsequently, The Case Was Selected For Limited Scrutiny Through Cass & Statutory Notices Were Issued To The Assessee. During The Course Of Assessment Proceedings, The Assessee Submitted That He Earned An Agriculture Income Of Rs. 23,10,000/- & This Receipt Was Deposited In Cash To Pay For The Bills Of Credit Care In His Bank Located In Delhi. On Perusal Of The Submissions Filed By The Assessee It Was Observed By The Ao That The Assessee Earned Agriculture Income In Cash Nellipudi Village, Andhra Pradesh. In Response To Requisite Notices, Ao Noted

For Appellant: Sh. Rajat Jain, CA & Sh. Akshat Jain, CAFor Respondent: Shri Manoj Kumar, Sr. DR
Section 69C

filed his return of income for the assessment year 2017-18 on 31.10.2017, declaring total income of NIL. Subsequently, the case was selected for Limited scrutiny through CASS and statutory notices were issued to the assessee. During the course of assessment proceedings, the Assessee submitted that he earned an agriculture

Shri Laxmi Saraswati Credit Co-Op Society, Uttar Kannada vs. Income Tax Officer, Ward - 2, Karwar

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

ITA 147/PAN/2025[2017-18]Status: DisposedITAT Panaji10 Sept 2025AY 2017-18

Bench: Shri Pavan Kumar Gadalei T A. Nos.147/Pan/2025 (A.Y. 2017-18 ) Laxmi Saraswati Credit Vs Ito-Ward-2, Cooperative Society , 1 St Floor,Santeri . Anjuman College Road, Krupa, Kalga Road, Bhatkal, Uttarakannada, Habbuwada,Karwar, Karnataka-581320. Uttara Kannada- Karnataka-581306. Pan .No. Aaeas2562C (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Varun Bhat.Ar Revenue By Smt.Manju Thakur.Sr.Dr सुनवाई की तारीख/Date Of Hearing 09.09.2025 घोषणा की तारीख/Date Of Pronouncement 10.09.2025 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of The Addl /Jcit(A) Prayagraj Passed U/Sec 143(3) & U/Sec 250 Of The Act. 2. At The Time Of Hearing, The Ld.Ar Of The Assessee Submitted That There Is A Delay In Filing The Appeal Before The Hon’Ble Tribunal & The Assesse Has Filed The Application & Affidavit For Condonation Of The Delay. Whereas, The Facts Mentioned In The Affidavit Are Reasonable & The Ld. Dr Has No Specific Objections. Accordingly, We Condone The Delay & Admit The Appeal. The Assesse Has Raised The Grounds Of Appeal Challenging

disclosing a total income of Rs.Nil after claiming deduction u/sec 80P of the Act of Rs.23,20,646/-.Subsequently the case was selected for limited scrutiny under CASS and notice u/sec143 (2) and u/sec 142(1) of the Act are issued calling for details in respect of claims

Satyapal Singh Chauhan HUF, Ambala Cantt vs. Income Tax Officer, Ward-4 Ambala, Income Tax Office, Ambala

In the result, appeal of the Assessee is allowed

ITA 715/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh09 Sept 2025AY 2020-21

Bench: Us:- "1. That The Ld. Pcit Has Erred On Facts & In Law In Exercising Revisionary Powers U./S 263. 2. That The Ld. Pcit Has Erred In Law & Facts In Holding That The Case Is Covered Under Clause (1) Of Explanation 2 Of Section 263(1). 3. That Appellant Craves Leave To Add, Alter, Amend Or To Substitute The Above Grounds Of Appeal Either Before Or At The Time Of Hearing Of Case." 2. The Facts, In Brief, Are That The Assessee Huf Have Been Filing The Returns Year After Year Disclosing Agricultural Income Besides Normal Rental Income. Agricultural Income Disclosed In The Previous Years & In The Year Under Consideration Is As Under:-

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Kusum Bansal, CIT, DR (Virtual Mode)
Section 143(1)Section 143(3)Section 263Section 263(1)

dated 16.09.2022. At page- 1 of the order, it has been mentioned that the case was taken for 'limited scrutiny' under CASS to verify the issue of agricultural income and, thereafter, the detailed questionnaire was issued as per copy placed at pages 35 to 37 of the Paper Book, alongwith ... advanced before us. The undisputed facts are that the AO was very much conscious of the factthat the case has been taken under limited scrutiny for verification of agricultural income as disclosed by the assessee and in consequent thereof, he had issued a detailed questionnaire to which, the assessee replied