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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Neotiss Private Limited, Medak vs. ACIT, Circle 8(1), Hyderabad

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

ITA 436/HYD/2023[2016-17]Status: DisposedITAT Hyderabad20 Aug 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.436/Hyd/2023 (निर्धारण वर्ा/Assessment Year: 2016-17) Neotiss Private Limited Vs. Acit Medak Circle-8(1) Pan : Aaacc8221G Hyderabad

For Appellant: Shri Sashank Dundu, ARFor Respondent: Shri Siva Prasad SV, DR

Section 142(1)Section 40

facts of the case. 2. The NFAC ought to have appreciated that the scrutiny proceedings having been initiated on three specific issues (limited scrutiny), the Assessing Officer erred in traversing beyond the three issues while completing the assessment, more particularly when no specific addition was made with reference ... issues to be considered in the limited scrutiny proceedings. 3. The NFAC ought to have noticed that the royally payment is based on the comprehensive agreement between the Parent company and Appellant company and hence the payment made by the Appellant on scrap sales is business decision, resultantly, Assessing Officer

Dr. Om Prakash, Delhi vs. ACIT, Circle- 2, Ghaziabad

In the result, the appeal of the assessee is allowed

ITA 402/DEL/2018[2014-15]Status: DisposedITAT Delhi20 Aug 2025AY 2014-15

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2014-15 Dr. Om Prakash, Vs. Acit, C/O. Kapil Goel, Adv. Circle-2. F-26/124, Sector 7 Rohini, Ghaziabad Delhi-1100 85 Pan: Aecpp6941B (Appellant) (Respondent)

For Appellant: Dr. Kapil Goel, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 250Section 264

That on the facts and in the circumstances of the case and in law, ld CIT-A erred in not appreciating that limited scrutiny was vaguely and wrongly converted to complete scrutiny without following due process of law and extant CBDT instructions thus rendering additions beyond limited scrutiny

Vithalbhai Harjibhai Patel, Surat vs. ITO, Ward3(2)(4), Surat

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

ITA 138/SRT/2025[2016-17]Status: DisposedITAT Surat19 Aug 2025AY 2016-17

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.138/Srt/2025 Assessment Year: (2016-17) (Hybrid Hearing) Vithalbhai Harjibhai Patel, Vs. The Ito, 101-102, Harihari Society, Katargam Ward – 3(2)(4), Surat - 395004 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Abcpp0940K (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Kamlesh Bhatt, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 04/08/2025 Date Of Pronouncement 19/08/2025

Section 143(1)Section 143(2)Section 250Section 253(3)Section 271(1)(c)

return was processed u/s 143(1) of the Act, accepting the income declared by the assessee. The case was selected for limited scrutiny under CASS due to reason “Whether cash in hand shown in return of income is correct”. Various notices were issued

The Pursottam Farmers Co.Op. Cotton Ginning & Pressing Society Ltd., Surat vs. The Assistant Commissioner of Income Tax, Ciracle-2(2), Surat

In the result, the appeal of the assessee is allowed, whereas the appeal of the revenue is dismissed

ITA 523/SRT/2024[2017-18]Status: DisposedITAT Surat19 Aug 2025AY 2017-18

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.499/Srt/2024 Assessment Year: (2017-18) (Hybrid Hearing) Dcit, Vs. The Pursottam Farmers Co-Op. Circle – 2(1)(1), Cotton Grnning & Pressing Soc. Surat Ltd., Jahangirpura Gin., Jahangirpura, Rander – 395009, "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaat3000A (Appellant) (Respondent) आयकर अपील सं./Ita Nos.523/Srt/2024 Assessment Year: (2017-18) The Pursottam Farmers Co-Op. Vs. Dcit, Cotton Grnning & Pressing Soc. Ltd., Circle – 2(1)(1), Jahangirpura Gin., Jahangirpura, Surat Rander – 395009, "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaat3000A (Appellant) (Respondent) Appellant By Shri Ajay Uke, Sr. Dr Respondent By Shri Akshay M. Modi, Ca Date Of Hearing 23/07/2025 Date Of Pronouncement 19/08/2025

Section 143(3)Section 194A(3)(v)Section 250Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

after claiming deduction under Chapter VIA of Rs.2,65,23,665/-, which was restricted to the gross total income. The case was selected for limited scrutiny on the following issues: (i) deduction under Chapter VIA, (ii) bonus for commission paid to employees and (iii) disallowance of payment of gratuity

Dy. Commissoner of Income-Tax, Circle-2(1)(1), Surat vs. The Pursottam Farmers Co Op Cotton Grnning and Pressing Society Ltd, Surat

In the result, the appeal of the assessee is allowed, whereas the appeal of the revenue is dismissed

ITA 499/SRT/2024[2017-18]Status: DisposedITAT Surat19 Aug 2025AY 2017-18

Section 143(3)Section 194A(3)(v)Section 250Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

M/S Pramod Telecom Pvt.Ltd., Lucknow vs. DCIT/ACIT-3, Lucknow

In the result, in ITA. No

ITA 243/LKW/2022[2020-21]Status: DisposedITAT Lucknow19 Aug 2025AY 2020-21

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Rakesh Garg, AdvocateFor Respondent: Sh. Deepak Yadav, DR

Section 143(1)Section 143(1)(a)Section 143(3)Section 154Section 250Section 36(1)(va)Section 43B

before the due date under section 36(1)(va) of Rs. 29,16,547/-. 6. Thereafter, on 29.08.2019, the case was picked up for limited scrutiny and the matter was scrutinized on the issue of, ‘disallowance under section 40A(7)’. The ld. AO concluded the assessment with the finding that

M/S Pramod Telecom Pvt.Ltd., Lucknow vs. DCIT/ACIT-3, Lucknow

In the result, in ITA. No

ITA 242/LKW/2022[2018-19]Status: DisposedITAT Lucknow19 Aug 2025AY 2018-19

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Rakesh Garg, AdvocateFor Respondent: Sh. Deepak Yadav, DR

Section 143(1)Section 143(1)(a)Section 143(3)Section 154Section 250Section 36(1)(va)Section 43B

Atul Kumar Kala, Jaipur vs. ITO Ward 4(1) Jaipur, Jaipur

In the result, appeal of the Assessee is allowed as per the

ITA 30/JPR/2025[2017-18]Status: DisposedITAT Jaipur14 Aug 2025AY 2017-18

Bench: Dr. Manish Bo

For Appellant: Shri Sharwan Kumar Gupta, AdvFor Respondent: Shri Gautm Singh Choudhary

Section 115BSection 143(2)Section 154Section 234Section 250Section 69C

filed on 28/02/2018. Based on the information about cash deposits in the credit card account, the assessee’s case selected for limited scrutiny under CASS after serving of valid notices u/s. 143(2) and 142(1) of the Act. During the course of assessment proceedings, the assessee furnished various details

Roopa Lamba, Chandigarh vs. Income Tax Officer, Ward 1(3), Chandigarh

In the result, the appeal of the assessee is allowed

ITA 537/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh14 Aug 2025AY 2017-18

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Vineet Krishan, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

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

that the assessee filed her return of income declaring total income of Rs. 14,04,060/-. The case of the assessee was selected for limited scrutiny under CASS to examine cash deposits during the year under consideration. Thereafter, notices under section 143(2) and 142(1) were issued calling ... appeal before us. 4. During the course of hearing, the Ld. AR submitted that the case of the assessee was selected for limited scrutiny to examine cash deposits during the demonetization period. It was submitted that the necessary details were submitted during the course of assessment proceedings and no adverse

Dhairya Jyotish Dandwala, Ahmedabad vs. The ITO, Ward-5(2)(2), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 813/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad14 Aug 2025AY 2017-18

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2017-18

For Appellant: Shri Tej Shah, A.RFor Respondent: Shri Kamal Deep Singh, Sr. D.R

Section 133(6)Section 69C

advisor and director in real estate. The assessee also received income as advisor for catering business. The case of the assessee was selected for limited scrutiny for the reason large cash payments made for credit card purchases. Statutory notices were issued and the same was replied by the assessee

Ketan Priyavadan Shah, Ahmedabad vs. The ITO, Ward-1(2)(3), Ahmedabad

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

ITA 734/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad14 Aug 2025AY 2020-21

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokarasstt.Year : 2020-2021 Ketan Priyavadan Shah The Ito, Ward-1(2)(3) 6, Vidyanagar Co-Op Hsg. Society Vs. Vejalpur Ashram Road, Usmanpura Ahmedabad. Ahmedabad. Pan : Afgps 3703 K (Applicant) (Responent) : Shri Parin Shah, Ar Assessee By : Shri Atul Pandey, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 12/08/2025 घोषणा क" तारीख /Date Of Pronouncement: 14/08/2025

For Appellant: Shri Atul Pandey, Sr.DR

Section 143(3)Section 144BSection 234ASection 270ASection 271ASection 56(2)(x)Section 69

case 2.1 The assessee filed his return of income on 10.01.2021 declaring total income of Rs.6,90,340/-. The case was selected for limited scrutiny under 3 Officer, Chief Postmaster General v. Living Media India Ltd., and SRF Ltd. v. ACIT, he dismissed the appeal in limine without going into

Amitkumar Navnitbhai Patel, Ahmedabad vs. The ACIT, Circle-2(1)(1), Ahmedabad

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

ITA 984/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad14 Aug 2025AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.984/Ahd/2023 िनधा"रण वष" /Assessment Year : 2017-18 Amitkumar Navnitbhai Patel The Acit बनाम/ A/1-1, Madhav Apartment Circle 2(1)(1) V/S. Opp. Municipal Garden Ahmedabad – 380 015 Vasna Ahmedabad – 390 007 "थायी लेखा सं./Pan: Amppp 5605 F अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri P.F. Jain, Ca Revenue By : Shri Atul Pandey, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 13/08/2025 घोषणा की तारीख /Date Of Pronouncement: 14/08/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Shri P.F. Jain, CAFor Respondent: Shri Atul Pandey, Sr.DR

Section 115BSection 143(3)Section 69Section 69A

filed his return of income for the A.Y. 2017-18 on 30.10.2017 declaring total income of Rs.2,63,520/-. The case was selected for limited scrutiny. During the course of assessment proceedings, the Assessing Officer noticed cash deposits aggregating to Rs.18,66,500/- in the assessee’s bank account during ... ground of appeal. 6. During the course of hearing before us the learned Authorized Representative submitted that the assessee’s case was selected for limited scrutiny for the specific purpose of verification of (a) cash deposits made during the demonetization period, and (b) purchase/sale of immovable property. The first notice

Chourasiainfratech Pvt Ltd., Bengaluru vs. DCIT, Circle-2(1)(1), Bengaluru

In the result, the appeal is treated as allowed for statistical purposes

ITA 317/BANG/2025[2015-16]Status: DisposedITAT Bangalore14 Aug 2025AY 2015-16

Bench: Shri Narender Kumar Choudhry & Shri Waseem Ahmedassessment Year: 2015-16

For Appellant: Shri Y Pranay Sharma, AdvocateFor Respondent: Shri Balusamy N, JCIT

Section 133(6)Section 143(2)Section 144Section 246ASection 250Section 253(3)

income for the A.Y 2015-16 on 31.05.2016 declaring gross total income of Rs.77,48,120/-. 2. The Appellant's case was selected for limited scrutiny through CASS and the issue for 08 selection is to verify "Cash deposit" Notice was issued to Appellant under section

Shri Adinath Multipurpose, Belagavi vs. Income Tax Officer, Ward - 1, Gokak

In the result, the two appeals filed by the assessee are allowed for statistical purpose

ITA 112/PAN/2025[2020-21]Status: DisposedITAT Panaji13 Aug 2025AY 2020-21

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member), SHRI G D PADMAHSHALI (Accountant Member)

Section 80P(2)(a)

disclosing a total income of Rs. Nil after claiming deduction u/sec 80P of the Act.Further the case was selected for limited scrutiny and the A.O has issued notice u/sec142(1) of the Act calling for details in respect of claims and the information supporting the return of income filed

Shri Adinath Multipurpose, Belagavi vs. Income Tax Officer, Ward - 1, Gokak

In the result, the two appeals filed by the assessee are allowed for statistical purpose

ITA 111/PAN/2025[2018-19]Status: DisposedITAT Panaji13 Aug 2025AY 2018-19

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member), SHRI G D PADMAHSHALI (Accountant Member)

Section 80P(2)(a)

Destiny Private Limited, Kolkata vs. ITO, Ward 6(1), Kolkata

Appeal of the assessee is allowed for statistical purposes

ITA 1245/KOL/2025[2016-2017]Status: DisposedITAT Kolkata13 Aug 2025AY 2016-2017

Section 142(1)Section 250

well as on facts to affirm the validity of assessment order made by AO without jurisdiction by enlarging the scope of limited scrutiny case. 2. The Ld. CIT(A) erred in law by not considering the facts that the assessment is passed on the ground which was never ... notice under Section 143(2) of the Act dated 18.09.2017, it is clearly indicated that the case was picked up for “limited scrutiny". It was argued that the Ld. AO travelled beyond the scope of such limited scrutiny and made the impugned addition. It was further argued that the assessee

Shree Karavasav Shivacharya Pattin Sahakar Sangh Ni Baradol, Bijapur vs. Income Tax Officer, Ward-2, Bijapur

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

ITA 588/BANG/2025[2016-17]Status: DisposedITAT Bangalore13 Aug 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2016-17

For Appellant: Ms. Sunaina Bhatia, AdvocateFor Respondent: Shri Ganesh R Ghale - Advocate, Standing

Section 80PSection 80P(2)(a)

after claiming deduction under section 80P(2)(a)(i) of the Act for Rs. 18,29,480/- only. 5. The return was selected for limited scrutiny to verify the deduction claimed by the assessee under section 80P(2)(a)(i) of the Act. The AO from the financial statement

Zodiac Ventures Limited, Mumbai vs. Income Tax Officer- 11 (3) (1), Mumbai

The appeal of the assessee is allowed

ITA 4135/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Aug 2025AY 2017-18

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri S. C. Tiwari, AR

Section 143(1)Section 14ASection 199Section 250

A.Y.2017-18 on 14.10.2017, declaring total income at Rs.8,96,880/-. The return was processed u/s 143(1) by CPC. The case was selected for limited scrutiny and the statutory notices were duly served on the assessee. The AO during the course of proceedings noticed that the assessee has made investments

Shreeji Ceramic Industries, Morbi vs. The Principal Commissioner of Income Tax-1, Rajkot

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

ITA 266/RJT/2024[2015-16]Status: DisposedITAT Rajkot12 Aug 2025AY 2015-16

Bench: Dr. A.L.Saini, Am & Diesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.266/Rjt/2024 ("नधा"रणवष" / Assessment Year: (2015-16) (Hybrid Hearing) Shreeji Ceramic Industries, The Principal Commissioner Of Vs. 8/A National Highway, Lalpar Income Tax – 1, Morbi - 363642 Rajkot "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalfs8846B (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Sanjay Punglia, Cit (Dr) सुनवाईक"तार"ख/ Date Of Hearing : 17/07/2025 घोषणाक"तार"ख/Date Of Pronouncement : 12/08/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm: This Appeal Has Been Filed By The Assessee Against The Order Of Learned Principle Commissioner Of Income Tax, Rajkot – 1 [In Short, “The Ld. Pcit”], Dated 30.03.2021 For The Assessment Year (Ay) 2015-16. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows.

For Appellant: Shri D. M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT (DR)

Section 142(1)Section 143(2)Section 143(3)Section 144Section 263Section 263o

Principal Commissioner of Income Tax, Rajkot-1erred in stating that the assessment order u/s 143(3) was under complete scrutiny although it was under ‘limited scrutiny’ as evident from the notice u/s. 143(2) read with the assessment order u/s. 143(3) of the Act. 3. The learned Principal Commissioner ... Rajkot-1 erred in assuming jurisdiction u/s. 263 on an issue of S. 40A(3) which was ipso facto beyond the scope of limited scrutiny issues u/s 143(3) order. 4. The appellant craves leave to add, amend, alter and withdraw any ground of appeal anytime up to the hearing

Junaid Suleman Motara, Na vs. Arivs.the Income Tax Officer, Ward - 3, Navsari

In the result, both the appeals of the assessee are allowed for statistical

ITA 674/SRT/2023[2016-17]Status: DisposedITAT Surat12 Aug 2025AY 2016-17

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethsaa 3Ittt F./Ita Nos. 567 & 674/Srt/2023 (Ays 2015-16 & 2016-17) (Hybrid Hearing) Junaid Suleman Motara Assistant Commissioner Of 27, Vohra Wad Telada Vesma, Income-Tax, Osd, Ward-3, Navsari-396 445 Navsasi Ranga Puja Complex, 1* [Pan : Bxupm 1984 R] Floor, Junathana Navsari-396 445 Colt Vs Income Tax Officer, Ward-3, Income Tax Office, Charpool, Awabaug, Navsari-396 445 Ardenelf/ Appellant Weet Respondent Prafftdt #1 Sik A /Assessee By Shri P.M. Jagasheth, Ca Weed Bt Ix S /Revenue By Shri Ajay Uke- Sr-Dr | Aare Ct Artg/Date Of Hearing 24.07.2025 Squrgun Ct Arrg/Date Of Pronouncement 12.08.2025

Section 133(6)Section 143(3)Section 250Section 253(1)Section 254(1)

agriculture income of Rs.72,4,146/-. After processing return u/si43(1) of the Act, the appellant’s case was taken up for limited scrutiny assessment through CASS by issuing notice u/s 143(2) of the Act dated 16.09.2017. During the year under consideration, the appellant engaged in the agriculture activities