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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Anubhav Kumar, Ranchi vs. ITO 1(1), Ranchi

Appeal of the assessee is allowed

ITA 396/RAN/2024[2017-18]Status: DisposedITAT Ranchi08 Sept 2025AY 2017-18

Bench: Shri Sonjoy Sarma, Jm & Shri Ratnesh Nandan Sahay, Am (Through Hybrid Mode) आयकर अपील सं./Ita No.396/Ran/2024 ("नधा"रण वष" / Assessment Year :2017-2018) Anubhav Kumar, Vs. Ito-1(1), Ranchi 18, Darjee Mohalla Doranda, Ranchi-834002 "थायी लेखा सं./Pan No. :Arvpk 4816 C (अपीलाथ" /Appellant) .. (""यथ" / Respondent) िनधा"रती की ओर से /Assessee By : Shri Akshay Ringasia, Ar राज"व क" ओर से /Revenue By : Shri Khubchand T Pandya, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing : 03/09/2025 घोषणा क" तार"ख/Date Of Pronouncement : 08/09/2025 आदेश / O R D E R Per Sonjoy Sarma, Jm : The Above Captioned Appeal Is Filed By The Assessee Against The Order Dated 21.08.2024, Passed By The Ld. Addl./Jcit(A)-8, Mumbai For The Assessment Year 2017-2018. 2. The Assessee Is An Individual Filed His Income Tax Return For The Assessment Year 2017-2018 Showing Total Income At Rs.5,23,718/-.The Return Of The Assessee Was Processed On The Same Income As Declared By The Assessee. The Case Of The Assessee Was Selected For Limited Scrutiny On The Reason That Large Value Of Cash Deposit Made During The Demonetization Period. The Assessee Had Deposited Rs.10,42,000/- In Cash During The Period From 09.11.2016 To 31.12.2016 By The Assessee In Various Accounts Maintained By The Assessee. The Assessee Made Compliance To The Notice Issued By The Ao In Order To Substantiate The Claim

For Appellant: Shri Akshay Ringasia, ARFor Respondent: Shri Khubchand T Pandya, Sr. DR
Section 69A

return of the assessee was processed on the same income as declared by the assessee. The case of the assessee was selected for limited scrutiny on the reason that large value of cash deposit made during the demonetization period. The assessee had deposited Rs.10,42,000/- in cash during

Kesar Buildcon Private Limited, Banaskantha vs. The PCIT, Ahmedabad-3, Ahmedabad

Accordingly, we set aside the order passed by the PCIT and restore the assessment order passed by the Assessing Officer. The appeal of the assessee is thus allowed

ITA 790/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad08 Sept 2025AY 2021-22

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2021-2028 Kesar Buildcon Pvt. Ltd. The Ld.Pr.Cit 1St Floor Shri Kesar Cold Vs. Ahmedabad-3 Storage Plot No.B-2 To 9, Rev Survey No.85/2 Paiki Near Hotel Jyoti Vil Banaskantha. Pan : Aabck 4923 E (Applicant) (Responent) : Shri Hem Chhajed, Ar Assessee By : Shri Rignesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 03/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 08/09/2025

For Appellant: Shri Rignesh Das, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 2(22)(e)Section 263Section 269S

dated 13.10.2021 issued by the CBDT, which lays down the modalities for conducting assessments under the Faceless Assessment Scheme and delineates the scope of limited scrutiny, complete scrutiny and compulsory scrutiny cases. Point No. 10, as reproduced from the Instruction, reads as under: “Notice u/s. 143(2) in scrutiny cases ... restricted by the system to 8 those very issues. Thus, the statutory scheme and CBDT’s own instructions both emphasise that the scope of limited scrutiny is sacrosanct and cannot be enlarged except with prior approval of the competent authority. 5.6 We also examined the “Proceedings Feedback” from the ITBA

Dineshwar Prasad, Sarvadya Kamla Apartment, Boring Road vs. Deputy Commissioner of Income Tax, Circle-4, Patna, Not Known

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

ITA 250/PAT/2025[2014-15]Status: DisposedITAT Patna01 Sept 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.250/Pat/2025 Assessment Year: 2014-15 Dineshwar Prasad.………………………. …………………....Appellant Sarvadya Kamla Apartment, An Path, North S K Puri, Boring Road, Patna - 800013. [Pan: Acwpp8473C] Vs. Dcit, Circle-4, Patna…..…..……………..………………….…..... Respondent Appearances By: Shri S.S.P Singh, Fca Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 18, 2025 Date Of Pronouncing The Order : September 1St, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 21.02.2023 Passed By The Nfac, Delhi Under Section 250 Of The Income-Tax Act, 1961. 2. At The Outset, It Is Noted That There Is A Delay Of 749 Days In Filing The Present Appeal Before The Tribunal. The Assessee Has Filed A Condonation Petition Explaining The Reasons Or Such Delay. After Considering The Submissions & Materials On Record, We Are Satisfied That There Was Reasonable Cause For The Delay In Filing The Appeal. Accordingly, The Said Delay Is Condoned & The Appeal Is Admitted For Adjudication.

Section 250Section 69

return of income for the assessment year 2014-15 by declaring a total income of Rs.8,87,760/-. Subsequently, the case was selected for limited scrutiny through CASS and notice under Sections 143(2) and 142(1) were issued calling for details and documents in respect of cash deposits