← All Phrases

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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Mahasakthi Bio Enercon Pvt. Ltd., Coimbatore vs. ACIT, Central Circle-1, Coimbatore

In the result, the appeal of the assessee is allowed

ITA 467/CHNY/2025[2013-14]Status: DisposedITAT Chennai15 Jul 2025AY 2013-14

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:467/Chny/2025 िनधा"रण वष" / Assessment Year: 2013-14 Mahasakthi Bio Enercon Private Assistant Commissioner Of Limited, Vs. Income Tax, No.64, Dr. Nanjappa Road, Central Circle -1, Coimbatore – 641 018. Coimbatore. [Pan:Aabci-0022-N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri. T. Banusekar, Advocate ""थ" की ओर से/Respondent By : Ms. E. Pavuna Sundari, C.I.T.

For Appellant: Shri. T. Banusekar, AdvocateFor Respondent: Ms. E. Pavuna Sundari, C.I.T
Section 147Section 148Section 151Section 263

Jurisdictional Tribunal wherein it is held that Assessing Officer cannot travel beyond the issues on which assessment has been taken up for limited scrutiny. Therefore, once the Assessing Officer does not have power to go beyond the issues on which he has taken up case for scrutiny, then obviously ... Yuvaraj v. ITO (ITA No.1722/CHNY/2019) and Subbunadar Chandrasekar v. ITO (ITA No.612/CHNY/2021) have reiterated the principle that when assessment is initiated for a limited scrutiny or reassessment, the AO cannot travel beyond the specific issue(s) for which the case was reopened, unless such scope is expressly expanded. Consequently

K Mordani Constructions Private Limited (Formerly Known As K Mordani Constructions LLP), Mumbai vs. DCIT 22(1), Mumbai

In the result, the appeal is allowed for statistical purposes

ITA 1737/MUM/2025[2018-19]Status: DisposedITAT Mumbai14 Jul 2025AY 2018-19

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhriआयकर अपील सुं./Ita No. 1737/Mum/2025 (नििाारण वर्ा / Assessment Year :2018-19) K Mordani Constructions V/S. Additional/Joint/Deputy/ Private Limited (Formerly बिाम Assistant Commissioner Of Known As K Mordani Income Tax/Income-Tax Constructions Llp) Officer, National E- Office No. 105, 1St Floor, Assessment Centre, Delhi, Amore Commercial Dcit22(1) Premises Co-Op. Soc. Ltd., Piramal Chambers, Mumbai Junction Of 2Nd & 4Th Road Khar (West), Mumbai -400052 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aalfk2128G Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: Shri Ajay R. Singh A/W Shri Akshay Pawar राजस्व की ओर से /Revenue By: Shri Hemanshu Joshi, Sr. Dr.

For Appellant: Shri Ajay R. Singh a/w ShriFor Respondent: Shri Hemanshu Joshi, Sr. DR
Section 143(3)Section 250Section 40

that the assessee filed its return declaring income of Rs. 13,40,820/- on 25.03.2019 for A.Y. 2018-19. The case was selected for limited scrutiny and assessment was completed at an income of Rs. 7217205/- vide order u/s. 143(3) dated 16.04.2021 after making addition

Integra Automation Private Limited, Coimbatore vs. Corporate Circle 1(1) Che, Chennai

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

ITA 1091/CHNY/2025[2018-2019]Status: DisposedITAT Chennai10 Jul 2025AY 2018-2019

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.1091/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 M/S. Integra Automation Private Vs. The Assistant Commissioner Of Limited, Sf 238, Kurunallipalayam Income Tax, Village, Kinathukadavu, Negamam S.O. Corporate Circle 1(1), Emmegoundenpalayam, Coimbatore. Coimbatore 642 120. [Pan:Aaaci7412H] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri B. Sivaraman, C.A. ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 02.07.2025 घोषणा की तारीख /Date Of Pronouncement : 10.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.02.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2018-19. 2. The Assessee Raised 7 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is 2

For Appellant: Shri B. Sivaraman, C.AFor Respondent: Ms. R. Anita, Addl. CIT
Section 143(3)Section 69A

return of income for the AY 2018-19 declaring income of ₹.9,46,86,290/-. The return filed by the assessee was selected for limited scrutiny to verify the claim of any other amount allowable as deduction in Schedule BP, expenditure of personal nature and duty drawback. Against statutory notices

Karam Vir Yadav, Gurgaon vs. Assessing Officer, NFAC

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

ITA 2605/DEL/2024[2020-21]Status: DisposedITAT Delhi09 Jul 2025AY 2020-21

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmakaramvir Yadav, Vs. Assessing Officer, 1135, Sector 46, Nfac, Delhi. Gurgaon – 122 001 (Haryana). (Pan : Abipy5863E) (Appellant) (Respondent) Assessee By : Shri Ranjan Chopra, Ca Revenue By : Shri Kailash Dan Ratnoo, Cit Dr Date Of Hearing : 30.04.2025 Date Of Order : 09.07.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 29.03.2024 For Assessment Year 2020-21 Raising Following Grounds Of Appeal :- “1. That Having Regard To The Facts & Circumstances Of The Case & In Law, The Order Under Section 263 Of The Income-Tax Assessee Company, 1961. 2. That Having Regard To The Facts & Circumstances Of The Case & In Law, The Learned Pr. Cit Erred In Passing Order U/S 263 Of The Act, So Much So That, The Assessment Order Passed By The Assessing Officer Do Not Satisfy The Statutory Twin Conditions Prescribed Under Section 263 Of The Act, Viz., (I) That The Assessment

For Appellant: Shri Ranjan Chopra, CAFor Respondent: Shri Kailash Dan Ratnoo, CIT DR
Section 143(3)Section 263Section 28

assessee is in appeal before us. 7. At the time of hearing, ld. AR of the assessee submitted that the case was selected for limited scrutiny and further he submitted that assessee had received compensation of Rs.2,94,34,541/- and claimed the same as exempt

Arjun Rishi, Sainik Farms vs. ITO Ward 28(1), ITO Office Civic Centre

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

ITA 3020/DEL/2023[2017-18]Status: DisposedITAT Delhi09 Jul 2025AY 2017-18

Bench: Shri Vikas Awasthy & Shri S. Rifaur Rahmanarjun Rishi, Vs. Ito, Ward 28 (1), F – 79/18, Sainik Farms, Delhi. New Delhi – 110 062. (Pan : Agvpr4625D) (Appellant) (Respondent) Assessee By : Shri Arun Kishore, Ca Revenue By : Shri Ashish Tripathi, Sr. Dr Date Of Hearing : 24.04.2025 Date Of Order : 09.07.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 01.09.2023 For Assessment Year 2017-18 Raising Following Grounds Of Appeal :- “1. I) That The Order Of Ld. Cit (A) Nfac Delhi Confirming The Addition Of Rs.9,81,173/- Made By Ld. Ao Ward 28(1) Delhi Is Illegal, Unjust, Opposed To Facts & Suffers From The Vice Of Arbitrariness. Ii) That All Grounds Of Appeal Are Independent & Without Prejudice To Each Other.

For Appellant: Shri Arun Kishore, CAFor Respondent: Shri Ashish Tripathi, Sr. DR
Section 124(3)Section 127Section 143Section 143(2)Section 143(3)Section 68

That the Ld. CIT (A) and Ld. AD have both grossly erred in ignoring the cash book filed and accepted during AY 2016-17 - limited scrutiny for verification of cash deposits. iv) That the inadvertent typing error in providing the information in the ITR for the first time