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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Ct. Ramanathan (HUF), Pudukkottai vs. PCIT 1, Madurai

Appeal of the assessee is allowed

ITA 761/CHNY/2025[2020-21]Status: DisposedITAT Chennai25 Jun 2025AY 2020-21

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.761/Chny/2025 Assessment Years: 2020-21 C.T.Ramanathan(Huf), Income Tax Officer, No.7/45, Ct.Rm.S.House, M.St.S. Street Ward-1, Kulipirai, Pudukottai Dist, Pudukottai. Tamil Nadu-622 402. [Pan: Aaahc0701L] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Mr.V.Subbarayan, Dcit(Retd.) प्रत्यर्थी की ओर से /Revenue By : Mr.M.K.Biju, Cir Dr By Virtual. सुनवाई की तारीख/Date Of Hearing : 03.06.2025 घोषणा की तारीख /Date Of Pronouncement : 25.06.2025 आदेश / O R D E R

For Appellant: Mr.V.Subbarayan, DCIT(Retd.)For Respondent: Mr.M.K.Biju, CIR DR by virtual
Section 143(3)Section 263Section 3

admitting total income of and agriculture income of from the sale of people and coffee the case was selected for limited scrutiny under CASS to verify the substantial increase Rs.5,17,720/- and in agriculture income of Rs.44,45,784/- from the sale of pepper and coffee. The assessment ... income of Rs.5,17,720/- and agricultural income of Rs.44,45,784/- from the sale of pepper and coffee. The case was selected for limited scrutiny under CASS to verify the substantial increase in agricultural income. The assessment was completed under section 143(3) r.w.s. 144B of the I.T.Act

Mani Shanthi, Namakkal vs. ITO, Circle-1, Erode

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

ITA 1224/CHNY/2025[2020-21]Status: DisposedITAT Chennai25 Jun 2025AY 2020-21

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.1224/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Mani Shanthi, Vs. The Income Tax Officer, 40, Perumal Koil Street, Circle 1, Sendamangalam, Namakkal 637 407. Erode. [Pan:Ajnps2143N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Senthil Kumar, Advocate ""थ" की ओर से/Respondent By : Shri Vijay Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 18.06.2025 घोषणा की तारीख /Date Of Pronouncement : 25.06.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 12.10.2023 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2020-21. 2. We Find That This Appeal Is Filed With A Delay Of 393 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, We

For Appellant: Shri Senthil Kumar, AdvocateFor Respondent: Shri Vijay Kumar, JCIT
Section 142(1)Section 143(2)Section 144

filed the return of income on 23.01.2021 declaring total income at ₹.35,99,480/- for AY 2020-21. The case was selected for limited scrutiny under CASS to verify the issue of agricultural income and issued notice under section 143(2) of the Income Tax Act, 1961 [“Act” in short

Krishnasamy Bhuvaneswari, Coimbatore vs. ITO, Non Corprate Ward 4(2), Coimbatore

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

ITA 1528/CHNY/2023[2013-14]Status: DisposedITAT Chennai25 Jun 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1528/Chny/2023 िनधा"रण वष" / Assessment Year:2013-14 Krishnasamy Bhuvaneswari, Ito, 43/63, Rajamanai Thottam, Vs. Non Corporate Ward 4(2), Kupanur, Mathampatty, Coimbatore. Coimbatore – 641 010. [Pan:Ahypb-5938-M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri. N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri. M. K. Biju, C.I.T. - D.R. सुनवाई की तारीख/Date Of Hearing : 05.06.2025 घोषणा की तारीख/Date Of Pronouncement : 25.06.2025

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. M. K. Biju, C.I.T. - D.R
Section 263Section 263(2)

that there was complete scrutiny of facts referred to in the revision order, considering the fact of selection of return of income filed for limited scrutiny proceedings, while passing the assessment order passed by the JAO and hence ought to have appreciated that the decision to direct ... vitiating the revision order. 8. The PCIT failed to appreciate that the decision rendered at para 5 of the impugned order to set aside limited scrutiny assessment order was wrong, erroneous, incorrect, invalid, unjustified and not sustainable both on facts and in law. 9. The PCIT failed to appreciate that

Rama University Uttar Pradesh, Kanpur vs. The Assessment Unit, Delhi

Appeal is allowed

ITA 86/DEL/2025[2020-21]Status: DisposedITAT Delhi25 Jun 2025AY 2020-21

Bench: Sh. Satbeer Singh Godaraita No. 86/Del/2025 : Asstt. Year : 2020-21 Ram University Uttar Pradesh, Vs The Assessment Unit, 2Nd Floor, E-Ramp, 100, Rama City, G. T. Road, Mandhana, U.P.-209217 Jawaharlal Nehru Stadium, New Delhi-110003 (Appellant) (Respondent) Pan No. Aadtr0638L Assessee By: Sh. Ashutosh Thakur, Adv. & Sh. Ritesh Kumar Singh, Adv. Revenue By : Ms. Indu Bala Saini, Sr. Dr Date Of Hearing: 25.06.2025 Date Of Pronouncement: 25.06.2025 Order This Assessee’S Appeal For Assessment Year 2020-21, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1067473637(1) Dated 09.08.2024, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Ashutosh Thakur, Adv. &For Respondent: Ms. Indu Bala Saini, Sr. DR
Section 143(2)Section 143(3)Section 57

course of assessment framed on 21.09.2022 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 Rama University Uttar Pradesh “registration/approval under various sections of IT Act has not been granted or has been cancelled/withdrawn ... 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