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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Mohammed Azhar, Nizamabad vs. ITO., Ward-1, Nizamabad

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

ITA 693/HYD/2025[2018-19]Status: DisposedITAT Hyderabad26 Aug 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: Dr. Sachin Kumar, SR-DR

Section 143(2)Section 143(3)Section 144Section 68

declaring total income of Rs.Nil and ITA No.693/Hyd/2025 3 agricultural income of Rs.33,30,102/-. The case of the assessee was selected for limited scrutiny for the reason of large agricultural income in comparison to the returned total income. Accordingly, notice under section 143(2) of the Income

Starpoint Vinimay Private Limited, Kolkata vs. Asst Commissioner of Income Tax (OSD) Ward-1(1), Kolkata

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

ITA 340/KOL/2025[2015-2016]Status: DisposedITAT Kolkata26 Aug 2025AY 2015-2016

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 143(3)Section 250Section 5

dealing in investment in shares and securities and the return declaring total income at ₹549/- was filed on 30.03.2016. The case was selected for limited scrutiny under Computer Assisted Scrutiny Selection (in short 'CASS') and the assessment was made by making an addition

R.K.Impex Private Limited, Kolkata vs. D.C.I.T., Circle-4(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2696/KOL/2024[2017-18]Status: DisposedITAT Kolkata26 Aug 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Rk Impex Private Limited Dcit, Circle 4(1) 2Nd Floor, 16A, P-7, Chowringhee Square, Synagogue Street Burra Bazar, Aayakar Bhavan, Kolkata-700069 Vs. West Bengal-700001 West Bengal (Appellant) (Respondent) Pan No. Aabcr2580A Assessee By : Shri Sunil Surana, Ar Revenue By : Shri Mangtinlen Haokip, Dr Date Of Hearing: 29.07.2025 Date Of Pronouncement: 26.08.2025

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Mangtinlen Haokip, DR

Section 143(2)

vehemently submitted that the notice u/s 143(2) of the Act vide order 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 instruction no. F. No. 225/157/2017/ITA-II

Allknown Marketers Private Limited, Mumbai vs. DCIT Circle 1(1)(1), Mumbai

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

ITA 2394/MUM/2025[2020-21]Status: DisposedITAT Mumbai26 Aug 2025AY 2020-21

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2020-21

For Appellant: Shri Rishi Agrawal, CAFor Respondent: Shri Surendra Mohan, Sr. DR

Section 133(6)Section 143(3)Section 234ASection 234BSection 68

noted that assessee filed its return of income on 06.01.2021 reporting total income at Nil. The reason for selection of the case for limited scrutiny was to examine unsecured loans received by the assessee. Assessee had taken unsecured loan of Rs.62,75,386/- from M/s. Ezeego One Travels and Tours

The Jamboti Multipurpose Co-Operative Society Limited, Belgaum vs. Pr. Commissioner of Income Tax, Hubbali

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

ITA 72/PAN/2023[2018-19]Status: DisposedITAT Panaji25 Aug 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos. 72/Pan/2023 (A.Y. 2018-19) Thejambotimultipurpose Vs Pr.Cit, Co-Operative Society Ltd, C.R.Building, . At Post,Jamboti, Navanagar, Khanapur, Belgaum Hubli-580025, Karnataka-591113 Karnataka . Pan/Gir No. Aaajt1994Q (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 143(3)Section 18(1)Section 263

total income of Rs.Nil/- after claiming deduction of Rs.25,59,276/- u/sec 80P of the Act. Further the case was selected for limited scrutiny under E-assessesment scheme-2019 on the issue-deduction from total income Under Chapter VA.And notice u/sec 143(2) and u/sec

Nikunjkumar Narbheram Thakkar, Taluka-Radhanpur, Dis-Patan, Gujarat vs. Ward 3, Patan (Present Juris. ITO Ward 1 Patan), Income Tax Department

In the result, appeal of the assessee is allowed

ITA 547/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad25 Aug 2025AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalnikunjkumar Narbheram Vs. Thakkar, The Income Tax Officer, 53, Nandanvan Bungalows, Ward 3, Patan Besides Bhabhar Tran Rasta, (Present Jurisdiction Radhanpur, Tal. Radhanpur, Ito, Ward 1, Patan) Radhanpur Dist. Patan [Pan :Agjpt 8348 K] (Appellant) .. (Respondent) Appellant By : Shri Sulabh Padshah, Ar Respondent By: Shri Prateek Sharma, Sr Dr Date Of Hearing 06.08.2025 Date Of Pronouncement 25.08.2025

For Appellant: Shri Sulabh Padshah, ARFor Respondent: Shri Prateek Sharma, Sr DR

Section 234ASection 250

income @ 8% of Rs. 1,56,57,359/- considering it as Undisclosed sales/receipt of Appellant. It is submitted that the case was selected for Limited Scrutiny Assessment on issue of verification of cash deposits and therefore the addition made on some different footing is completely out of scope and beyond ... jurisdiction of Limited Scrutiny Assessment. On facts circumstances of the case, the order passed by AO is incorrect and deserves to be quashed and addition made of Rs 12,52,589/-be deleted in interest of justice. The same please be held accordingly. Nikunjkumar Narbheram Thakkar Vs. ITO Asst. Year

Dhara Rakesh Sheth, Ahmedabad vs. Income Tax Officer, Ward 7(1)(1), Ahmedabad

In the result, appeal of the assessee is allowed

ITA 1186/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad25 Aug 2025AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyaldhara Rakesh Sheth, The Income Tax Officer, Vs. 9, Ashwini Apartment, Ward-7(1)(1), Tejendra Park, Ahmedabad. Naranpura, Ahmedabad-380013. [Pan : Bglps5238 L] (Appellant) .. (Respondent) Appellant By : None Respondent By: Shri Prateek Sharma, Sr. Dr Date Of Hearing 05.08.2025 Date Of Pronouncement 25.08.2025 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

For Appellant: NoneFor Respondent: Shri Prateek Sharma, Sr. DR

Section 142(1)Section 143(2)Section 144Section 69

income for A.Y.2016-17 was filed by the assessee on 05.08.2016, declaring total income at Rs. 2,10,000 /-. The case has been Selected under Limited Scrutiny (Computer Added Scrutiny Selection). Notice u/s.143(2) of the Act issued on 07/07/2017 and served upon the assessee by E-mail and speed post

Rajkumar Parshuram Mhatre, Poynad vs. Assessing Officer, Ward Panvel

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

ITA 1764/PUN/2025[2016-2017]Status: DisposedITAT Pune25 Aug 2025AY 2016-2017

Bench: Justice (Retd.) C V Bhadang & Shri R. K. Pandaassessment Year : 2016-17

For Appellant: Shri Ronak H JainFor Respondent: Shri Milind Debaje, JCIT

Section 143(2)Section 144Section 250(6)Section 68

individual and filed his return of income on 08.03.2017 declaring total income of Rs.3,15,020/-. The case 3 was selected for limited scrutiny under CASS. Accordingly statutory notices u/s 143(2) and 142(1) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) were issued

Sevugan Pethaperumal, Madurai vs. PCIT, Madurai-1, Madurai

In the result, the appeal of the assessee is allowed

ITA 1196/CHNY/2025[2020-21]Status: DisposedITAT Chennai25 Aug 2025AY 2020-21

Bench: Shri George George K & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1196/Chny/2025 Assessment Years: 2020-21 Sevugan Pethaperumal, Principal Commissioner Of Income No.41, First Main Street, Tax, Narayanapuram West, Madurai-1, Madurai, Madurai. Tamil Nadu-625 014. [Pan: Afjpp5984J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Shri G.Tarun, Advocate प्रत्यर्थी की ओर से /Revenue By : Shri Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 06.08.2025 घोषणा की तारीख /Date Of Pronouncement : 25.08.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Shri G.Tarun, AdvocateFor Respondent: Shri Bipin C.N, CIT

Section 143(3)Section 263

assessee on 25.08.2020. Order u/s 143(3) was passed by the Ld.AO on 12.09.2022 accepting returned income. Pertinently, the case was selected in the limited scrutiny category to examine the “deduction from other sources. Before the Ld.AO, the assessee had submitted that he is the owner of a property ... consideration. It has been clearly exhibited by the Ld.AO in opening para of his order that the assessee’s case was selected in the limited scrutiny category to examine the “deduction from income from other sources”. In the impugned limited scrutiny category an AO is mandated to only hold enquiries

Babita Sharma, Sonipat vs. Income Tax Officer, Ward-1, Sonipat

Appeal is allowed

ITA 4409/DEL/2025[2015-16]Status: DisposedITAT Delhi25 Aug 2025AY 2015-16

Bench: Sh. Satbeer Singh Godaraita No. 4409/Del/2025 : Asstt. Year : 2015-16 Babita Sharma, Vs Income Tax Officer, 582, Mission Road, Ward-1, Sonepat, Haryana-131001 Sonepat, Haryana-131001 (Appellant) (Respondent) Pan No. Cqeps0819R Assessee By: Sh. S. K. Jain, Adv. & Sh. Subodh Jain, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 25.08.2025 Date Of Pronouncement: 25.08.2025 Order This Assessee’S Appeal For Assessment Year 2015-16, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1074303204(1) Dated 10.03.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. S. K. Jain, Adv. &For Respondent: Sh. Manoj Kumar, Sr. DR

Section 143(2)Section 143(3)Section 147Section 48Section 54FSection 57

course of assessment framed on 23.03.2022 and upheld in the lower appellate proceedings, it emerges at the outset that it was a case of “limited” scrutiny on the issue of 2 Babita Sharma “substantial increase in capita during the year under consideration, mismatch in sales turnover reported in audit report ... contentions. I am of the considered view that once the impugned issue of section 57 or 48 deduction, disallowance nowhere formed subject matter of “limited” scrutiny exercise herein, both the learned lower authorities could not have disallowed the same herein in light of PCIT Vs. Weilburger Coatings India

Shri Gaushala Baba Phulu Sadh, Jind, Haryana vs. ITO Ward-1, Jind, Haryana

Appeal is allowed

ITA 4320/DEL/2025[2016-17]Status: DisposedITAT Delhi25 Aug 2025AY 2016-17

Bench: Sh. Satbeer Singh Godaraita No. 4320/Del/2025 : Asstt. Year : 2016-17 Sh. Gaushala Baba Phulu Sadh, Vs Income Tax Officer, Uchana Khurd, Jind, Ward-1, Haryana-126102 Jind, Haryana-126102 (Appellant) (Respondent) Pan No. Aagts5155E Assessee By: Sh. Ashok Kumar Goyal, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 25.08.2025 Date Of Pronouncement: 25.08.2025 Order This Assessee’S Appeal For Assessment Year 2016-17, Arises Against The Addl./Jcit(A)-3, Mumbai’S Din & Order No. Itba/Apl/S/250/2025-26/1075626735(1) Dated 15.04.2025, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Ashok Kumar Goyal, CAFor Respondent: Sh. Manoj Kumar, Sr. DR

Section 143(2)Section 143(3)Section 40A(3)Section 57

course of assessment framed on 26.10.2018 and upheld in the lower appellate proceedings, it emerges at the outset that it was a case of “limited” scrutiny on the issue of “large deduction 2 Shri Gaushala Baba Phulu Sadh claimed u/s 57 & large claim of depreciation for trust. Whether asset itself ... vehement contentions. I am of the considered view that once the impugned issue of section 57(iii) disallowance nowhere formed subject matter of “limited” scrutiny exercise herein, both the learned lower authorities could not have disallowed it in light of PCIT Vs. Weilburger Coatings India Pvt. Ltd. (2023) 155 taxmann.com

Monika Shekhri Mohalla Devi Asthan Noormahal Jalandhar, Punjab vs. The Income Tax Officer Ward-2, Jao the Income Tax Officer Ward-1 Phagwara, Punjab

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

ITA 524/ASR/2024[2017-2018]Status: DisposedITAT Amritsar22 Aug 2025AY 2017-2018

Bench: Sh. Udayan Dasgupta & Sh. Khettra Mohan Roy

For Appellant: Sh. Sudhir Sehgal, A.R

Section 143(3)Section 250Section 69A

also part of the record). 4. The return of the assessee was selected for scrutiny under CASS (as limited scrutiny) for verification of the cash deposited in bank during the demonetization period. In course of proceedings, submissions were filed explaining the source of cash deposit in bank account to have

Vaithav Arun Harnaskar, Pune vs. PCIT, Cir-5, Pune

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

ITA 1542/PUN/2025[2017-18]Status: DisposedITAT Pune22 Aug 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Pramod S ShingteFor Respondent: Shri Akhilesh Srivastva

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

appeal before this Tribunal. Assessee has filed an affidavit explaining the reasons stating as follows : “For AY 2017-18, the case was selected for limited scrutiny under CASS. Learned Assessing Officer has passed order u/s 143(3) dated 17.12.2019 wherein he has made various additions and assessed the income

Hamida Munir Chagani, Mumbai vs. ITO 24(2)(1), Mumbai

In the result, appeal of the assessee is allowed as per our aforesaid observations

ITA 4418/MUM/2025[2020-21]Status: DisposedITAT Mumbai22 Aug 2025AY 2020-21

Bench: Shri Amit Shukla & Shri Arun Khodpiaआयकर अपील सं. / Ita No.4418/Mum/2025 "नधा"रण वष" / Assessment Year :2020-21 Hamida Munir Chagani C-501, Green Park, Opp. New Link Road, Andheri (W), Mumbai-400 053 Pan :Aiapc7973L ........अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-24(2)(1), Mumbai ……""यथ" / Respondent

For Appellant: Shri Vimal PunmiyaFor Respondent: Shri Himanshu Joshi, Sr. DR

Section 143(3)Section 50CSection 50C(1)

year under consideration was filed on 26.12.2020, declaring total income at Rs.5,06,580/-. Subsequently, the case of the assessee was picked up for limited scrutiny which was culminated on 28.09.2022 after framing assessment u/s. 143(3) r.w.s. 144B of the Income Tax Act, 1961 (for short ‘the Act’), wherein

Fung Peng Namchoom, Chowkham vs. ITO, Ward - 1, Digboi

In the result, the appeals of the assessee are allowed for statistical purposes only

ITA 67/GTY/2025[2020-21]Status: DisposedITAT Guwahati21 Aug 2025AY 2020-21

Bench: Shri Rajesh Kumar, Hon’Ble & Shri Manomohan Das, Hon’Ble

For Appellant: Shri S.P. Bhati, FCAFor Respondent: Shri Kaushik Ray, JCIT

Section 10(1)Section 10(26)Section 115BSection 143(1)Section 250Section 69A

exempt business income of Rs. 31,12,493 u/s 10(26). The case of the assessee was selected for limited scrutiny due to (i) Large agricultural income without ITR filings for the past two years and (ii) Risk analysis of agricultural income. During the assessment, the learned Assessing Officer disallowed

DCIT, Central Circle-2, Jaipur vs. Kamlaprabha L/H of Late Shri Gopal Lal Ji Goswami, Kota

In the result, the appeal of the revenue is dismissed and the Cross objection of the assessee is disposed off in terms of the observation made herein above

ITA 94/JPR/2025[2014]Status: DisposedITAT Jaipur21 Aug 2025

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

For Appellant: Shri Mahendra Gargieya, AdvFor Respondent: Mrs. Alka Gautam, CIT-Sr.DR a

Section 144Section 153C

completed u/s 143(3) for AY 2014- 15, it is held that case of the assessee for AY 2014-15 was selected only for 'Limited Scrutiny' being reasons: (i) Large cash deposit in Saving Account (ii) Large deduction claimed u/s 5411, 54C, 54D, 546, 54GA, therefore, the other issues containing ... incriminating material/seized material are not open for the AO for assessment due to the limited scrutiny. Para 3: Regarding satisfaction note, since the satisfaction note was based on the finding as declared by the assessee on its own in the ITR filed for AY 2012-13. Further, AO only compare

India Construction, Diamond Harbour vs. ITO, Ward - 25(1), Kolkata

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

ITA 2592/KOL/2024[2018-19]Status: DisposedITAT Kolkata21 Aug 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 133(6)Section 143(3)Section 250

partnership firm and had filed the return of income showing total income of ₹53,17,130/- and the case was selected for limited scrutiny on the ground of’ high I.T.A. No.: 2592/KOL/2024 Assessment Year: 2018-19 India Construction. ratio of refund to TDS and low net profit shown by construction

Santoshi Subba Laxmi Mandala, Visakhapatnam vs. Income Tax Officer, Ward-1, Anakapalle

ITA 326/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam20 Aug 2025AY 2017-18

Bench: Us:

Section 131Section 147

belatedly, on 31.03.2018, declaring an income of Rs. 3,45,400/-. Subsequently, the case of the assessee was selected for limited scrutiny under CASS to examine the cash withdrawals made from her bank account during the year. 3. During the course of the assessment proceedings, the assessee on being queried

Gaytri Devi Sharma, Chomu vs. ITO Ward 7(3), Jaipur

In the result, the appeal of the assessee is allowed

ITA 512/JPR/2025[2017-18]Status: DisposedITAT Jaipur20 Aug 2025AY 2017-18

Bench: Him.

For Appellant: Sh. C. L. Yadav, CAFor Respondent: Sh. Gautam Singh Choudhary, JCIT

Section 133(6)Section 139Section 142(1)Section 144Section 250Section 44ASection 69A

basis of presumptions, the AO can not hold a particular deposit to be unexplained. 2.4 It is a trite law that the scope of Limited Scrutiny is confined, and it can not be extended. The case of the assessee was taken up for verification of cash deposited during demonetization ... passed under section 263 of the Income Tax Act, 1961, the Tribunal has held that the scope of 16 Gaytri Devi Sharma vs. ITO limited scrutiny is confined to its purpose and such an assessment cannot be treated as “erroneous” in order to invoke revisional jurisdiction. A bench

Usha Rani, Panchkula vs. Income Tax Officer, Ward-5, Panchkula

In the result, the appeal of the assessee is allowed

ITA 207/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh20 Aug 2025AY 2018-19

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 115BSection 143(3)Section 68

thus, untenable. 3. Briefly, the facts of the case are that the assessee has filed her return of income which was selected for limited scrutiny to examine agriculture income so reported in the return of income and thereafter, after issuing notice and calling for the necessary information and documentation ... agriculture income so reported in the impugned assessment year be accepted. It was submitted that the case of the assessee was selected for limited scrutiny to examine the agriculture income and therefore it was incumbent on the part of the AO to call for the necessary information and documentation