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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Mohammed Gyasuddin, Kolkata vs. ITO, Ward 30(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1053/KOL/2025[2017-2018]Status: DisposedITAT Kolkata25 Jul 2025AY 2017-2018

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyi.T.A. No. 1053/Kol/2025 Assessment Year: 2017-2018 Mohammed Gyasuddin,…………………………Appellant 3, Dent Mission Road, Kolkata-700023, West Bengal [Pan:Afvpg2465H] -Vs.- Income Tax Officer,……………….……….....Respondent Ward-30(2), Kolkata, Aayakar Bhawan, Dakshin, 2, Gariahat Road, Kolkata-700031 Appearances By: Shri Miraj D. Shah, A.R., Appeared On Behalf Of The Assessee Shri Abhijit Adhikari, Jcit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: July 22, 2025 Date Of Pronouncing The Order: July 25, 2025 O R D E R

Section 139(1)Section 143(2)Section 143(3)Section 40A(3)

facility for electronic conduct of assessment proceedings in a widespread manner from this financial year. 2. The three formats of notice(s) are: (i)Limited Scrutiny (Computer Aided Scrutiny Selection) (ii) Complete Scrutiny (Computer Aided Scrutiny Selection) (iii) Compulsory Manual Scrutiny The revised format of 143(2) notice(s) with ... ready reference, the operative part is reproduced below:- "12. A perusal of the above format would indicate that though in the heading, it exhibits limited scrutiny (Computer Aided Scrutiny Selection) but thereafter in the first paragraph, it only talks of scrutiny and then in second paragraph, it talks upon

Ganesh Mahato, Durgapur, South Parganas vs. Assistant Commission of Income Tax Circle 26(1), Kolkata

In the result, the appeal is allowed for statistical purposes, with cost of Rs

ITA 182/KOL/2024[2017-2018]Status: DisposedITAT Kolkata23 Jul 2025AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.182/Kol/2024 Assessment Year: 2017-18 Ganesh Mahato…...……………………..…………………....Appellant Vill. Durgapur, Po- Jaynagar, Majilpur, South 24 Parganas-743337. [Pan: Bgppm6996K] Vs. Acit, Circle-26(1), Kolkata ……………..………………….…..... Respondent Appearances By: Shri Ankit Jalan, Ar, Appeared On Behalf Of The Appellant. Shri Manas Mondal, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 23, 2025 Date Of Pronouncing The Order : July 23, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 01.12.2023 Passed By The Nfac [In Short Cit(A)] Under Section 250 Of The Income-Tax Act, 1961. 2. Brief Facts Of The Case Are That The Assessee Filed Return Of Income Declaring Total Income Of Rs.3,76,470/-. The Case Was Selected For Limited Scrutiny. Notices Under Sections 143(2) & 142(1) Were Issued But She Assessee Remained Non-Compliant. The Assessing Officer Observed That Total Deposits In The Assessee'S Bank Accounts With Bank During The Period April 2016 To March 2017 Amounted To Rs.2,00,80,900, Whereas The Assessee Had Shown Only Rs.90,20,200 As Sales. The Excess Deposit Of Rs.1,10,60,700 Was Treated As Unexplained Money Under Section 69A & Added To The Income Of The Assessee.

Section 144Section 250Section 69A

facts of the case are that the assessee filed return of income declaring total income of Rs.3,76,470/-. The case was selected for limited scrutiny. Notices under Sections 143(2) and 142(1) were issued but she assessee remained non-compliant. The Assessing Officer observed that total deposits

Waseem Alam, West Champaran vs. ITO, National E Assessment Centre, Delhi

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

ITA 17/PAT/2025[2018-19]Status: DisposedITAT Patna22 Jul 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.17/Pat/2025 Assessment Year: 2018-19 Waseem Alam…...………………….....…..…………………....Appellant Bhawanipur Kursi Barawa, Sikta, West Champaran, Bihar-845307. [Pan: Alopa0369B] Vs. Ito, Nfac, Delhi…………..……….…............................…..…..... Respondent Appearances By: Shri Sanjeev Kr. Anwar, Advocate, Appeared On Behalf Of The Appellant. Shri Ashwani Kumar, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 17, 2025 Date Of Pronouncing The Order : July 22, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 08.11.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Assessment Year 2018-19 Declaring Total Income Of Rs.9,68,550. The Return Was Processed Under Section 143(1) Of The Act. Subsequently, The Case Was Selected For Limited Scrutiny Under The E- Assessment Scheme, With The Specific Issue Of Verification Of Large Deduction Claimed Under Section 57 Of The Act. Notice Under Section 143(2) & Subsequently Under Section 142(1) Was Issued To The Assessee. Although The Assessee Uploaded Certain Documents Electronically In Response, The Details Were Found To Be Incomplete. The

Section 142(1)Section 143(1)Section 143(2)Section 250Section 57

declaring total income of Rs.9,68,550. The return was processed under section 143(1) of the Act. Subsequently, the case was selected for limited scrutiny under the e- assessment scheme, with the specific issue of verification of large deduction claimed under Section 57 of the Act. Notice under section

Vasudev Hargundas Tejwani, Vadodara vs. The ACIT, Circle-3(1), Vadodara

In the result, the appeal of the assessee is allowed in part

ITA 1060/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad22 Jul 2025AY 2017-18

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.1060/Ahd/2025 िनधा"रण वष" /Assessment Year : 2017-18 Vasudev Hargundas Tejwani The Acit बनाम/ Panchmukhi Mahadev Pole Circle-3(1) V/S. Opp. Jubilee Baug Vadodara – 390 007 Raopura Vadodara – 390 001 "थायी लेखा सं./Pan: Aavpt 5712 B (अपीलाथ'/ Appellant) ("( यथ'/ Respondent) Assessee By : Ms. Urvashi Shodhan, Ar Revenue By : Shri Kamal Deep Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 10/07/2025 घोषणा की तारीख /Date Of Pronouncement: 22/07/2025 आदेश/O R D E R Per Narendra Prasad Sinha, Am: This Appeal By The Assessee Is Directed Against The Order Dated 28/03/2025 Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As ‘Cit(A)’], Arising From The Assessment Order Dated 27/11/2019 Passed Under Section 143(3) Of The Income Tax Act, 1961 [Hereinafter Referred To As ‘The Act’] For The Assessment Year (Ay) 2017-18. Vasudev Hargundas Tejwani Vs. Acit Asst. Year : 2017-18

For Appellant: Ms. Urvashi Shodhan, ARFor Respondent: Shri Kamal Deep Singh, Sr.DR
Section 143(3)Section 234ASection 271ASection 68

assessee had filed the return of income for AY 2017-18 on 04/10/2017 declaring income of Rs.20,59,950/- The case was selected for limited scrutiny under CASS on the issue of cash deposit during demonetization period. It was found that the assessee had made cash deposit of Rs.14