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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Naresh Amarnath Barot, Ahmedabad vs. The ITO, Ward-3(3)(3), Ahmedabad

In the result, the appeal is allowed for statistical purposes

ITA 696/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad29 Jul 2025AY 2017-18

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2017-18 Naresh Amarnath Barot Ito, Ward-3(3)(3) C/O. Neela J. Rao Vs. Ahmedabad. 5, Ratanadeep Bungalow Nr.Sun-In Step Club Thaltej Ahmedabad 380054. Pan : Aaxpb 0044 N (Applicant) (Responent) : Assessee By Shri S.N. Divetia & Shri Samir Vora, Ars. Revenue By : Shri Umesh Kumar Agrawal, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 24/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 29/07/2025 आदेश आदेश/O R D E R आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal By The Assessee Is Directed Against The Order Passed By The National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”] Dated 14.02.2025, Under Section 250 Of The Income-Tax Act, 1961[Hereinafter Referred To As “The Act”], For The A.Y. 2017–18, Confirming The Addition Of Rs.19,59,000/- Made By The Assessing Officer Under Section 69A On Account Of Cash Deposits Made During The Demonetization Period As Per The Order Dated 09.12.2019 Passed Under Section 143(3) Of The Act.

For Respondent: Shri Umesh Kumar Agrawal, Sr.DR
Section 142(1)Section 143(2)Section 143(3)Section 250Section 69A

return of income on 12.01.2018 declaring income of Rs.1,05,150/- and agricultural income of Rs.1,38,240/-. The 2 case was selected for limited scrutiny under CASS for the reason “Cash deposits during demonetization period.” The Assessing Officer (AO) issued notices u/s 143(2) and several notices

Kailashchandra Haumanprasad Sugla, Solapur vs. ITO, Ward-1(1), Solapur

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

ITA 1555/PUN/2025[2015-16]Status: DisposedITAT Pune29 Jul 2025AY 2015-16

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.1555/Pun/2025 िनधा"रण वष" / Assessment Year: 2015-16 Kailashchandra Haumanprasad V The Income Tax Officer, Sugla, S Ward-1(1), Solapur. 45/15, Samrat Chowk, Budhwar Peth, Prabhakar Nagar H/S, Solapur-413001. Maharashtra. Pan: Ahsps3244B Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte – Ar Revenue By Shri Sandeep P Sathe – Jcit(Dr) Date Of Hearing 16/07/2025 Date Of Pronouncement 29/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(Appeal)-3, Chennai Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16Dated 12.10.2023, Emanating From Order U/S.143(3) Of The Income Tax Act, 1961, Dated 26.12.2017. The Assessee Has Raised Following Grounds Of Appeal :

Section 143(3)Section 250Section 272A(1)(c)Section 41(1)Section 56(2)(vii)

Assessing Officer erred in passing the order u/s 143(3) of the Income Tax Act, 1961 dated 26.12.2017, although the case was selected for limited scrutiny under CASS to verify the point of purchase of property, however learned Assessing officer has made various other additions without converting the same into

Veerendra Basavaraj Koujalagi, Belagavi vs. PCIT Hubballi, Hubballi

ITA 103/PAN/2024[2018-2019]Status: DisposedITAT Panaji28 Jul 2025AY 2018-2019

Bench: Hon’Ble Shri Pavankumar Gadale & Shri G. D. Padmahshaliita Nos. 103/Pan/2024 Assessment Year : 2018-19 Veerendra Basavaraj Koujalagi C/O. Shri Laxmi Complex, Sadashiv Nagar, Belgavi-590001 Pan : Agrpk3086D . . . . . . . Appellant V/S The Pr. Commissioner Of Income Tax, Hubali. . . . . . . . Respondent Appearances Assessee By : Mr Shivanand Halbhavi [‘Ld. Ar’] Revenue By : Capt. Pradeep Arya [‘Ld. Dr’] Date Of Conclusive Hearing : 24/06/2025 Date Of Pronouncement : 28/07/2025 Order Per G. D. Padmahshali; The Assessee’S Captioned Appeal Impugns Din & Order 1063626985(1) Dt. 29/03/2024 Passed By Pr. Commissioner Of Income Tax, Hubali [‘Ld. Pcit’] U/S 263 Of The Income-Tax Act, 1961 [‘The Act’] Which Sought To Revise Order Of Assessment Dt. 26/04/2021 Passed U/S 143(3) R.W.S. 144B Of The Act By National Faceless E-Asstt. Centre, Delhi [‘Ld. Ao’] Anent To Assessment Year 2018-19 [‘Ay’].

For Appellant: Mr Shivanand Halbhavi [‘Ld. AR’]For Respondent: Capt. Pradeep Arya [‘Ld. DR’]
Section 143(1)Section 143(2)Section 143(3)Section 14ASection 263

primary grievance in the present appeal loops round the powers of revisionary authority to revise an assessment order passed in pursuance of limited scrutiny assessment as against complete scrutiny. 3. Briefly stated facts born out of case records and as solidified by the rival parties are that; the assessee ... revisionary proceedings with a cannonball point that ‘format of notice issued u/s 143(2) of the Act by the Ld. AO was meant for ‘limited scrutiny’. It was alleged before the Ld. PCIT that, by the very nature of limited scrutiny assessment, the Ld. AO dealt with issues exclusively raised

Syed Zahed Ali, Hyderabad vs. ITO., Ward-14(1), Hyderabad

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

ITA 474/HYD/2025[2017-18]Status: DisposedITAT Hyderabad25 Jul 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.474/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2017-18) Shri Syed Zahed Ali, Income Tax Officer, Vs. Ward-14(1), Hyderabad. Hyderabad. Pan: Aifpa6433J (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Y.V. Bhanu Narayan Rao, C.A. रधजस् व द्वधरध/Revenue By: Sumitha Parmata, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 22/07/2025 घोर्णध की तधरीख/Pronouncement: 25/07/2025 आदेश/Order Per Madhusudan Sawdia, A.M. : This Appeal Is Filed By Shri Syed Zahed Ali (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Dated 05.02.2025 For The A.Y. 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal :

For Appellant: Shri Y.V. Bhanu Narayan RaoFor Respondent: Sumitha Parmata, SR-DR
Section 115BSection 133(6)Section 142(1)Section 143(2)Section 144Section 234Section 234BSection 250Section 69A

declaring total income of Rs.6,50,000/- under the head “income from other sources”. The case of the assessee was selected for limited scrutiny under CASS for the purpose of examining the sources of cash deposits, services fee received and cash withdrawals from bank. Accordingly, notice under section