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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Income Tax Officer, Delhi vs. Gsp Power Systems Pvt. Ltd., Delhi

Accordingly, the appeal fails and is dismissed

ITA 1273/DEL/2024[2018-19]Status: DisposedITAT Delhi03 Jun 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2018-19 Vs. Gsp Power Systems Pvt. Ltd., Income Tax Officer, New Delhi 22, 3Rd Floor, Main Market, Moti Nagar, New Delhi Pan: Aaccg0581H (Appellant) (Respondent) With C.O. No.40/Del/2024 [Arising Out Of Ita No.1273/Del/2024] Assessment Year: 2018-19 Gsp Power Systems Pvt. Vs. Income Tax Officer, Ltd., Ward-10(1), 22, 3Rd Floor, Main Market, New Delhi Moti Nagar, New Delhi Pan: Aaccg0581H (Appellant) (Respondent) Assessee By Dr. Rakesh Gupta, Adv. Sh. Somil Agarwal, Adv. Department By Ms. Suman Malik, Cit(Dr) Date Of Hearing 03.06.2025 Date Of Pronouncement 03.06.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No.1273/Del/2024 & Assessee’S Cross Objection C.O. No. 40/Del/2024 For Assessment Year 2018- 19, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The “Cit(A)/Nfac”], Delhi’S Din & Order No. Itba/Nfac/S/250/2023-24/1060727888(1), Dated 09.02.2024, Involving Proceedings Under Section 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Heard Both The Parties. Case Files Perused. 2. We Notice At The Outset That The Assessee’S Cross Objection Herein C.O. No. 40/Del/2024 Goes To The Root Of The Matter Since Challenging Validity Of The Impugned Assessment Itself Framed By The Learned Assessing Authority On 31St May, 2021. This Is For The Precise Reason That The Assessee’S Case Was Taken Up For Scrutiny On The Twin Issues Of Non-Furnishing Of Quantitative Details & “Investments/Advances/Loans” Whereas It Ended Up In Adding An Amount Of Rs.12,59,97,711/- As Unexplained Cash Credits Under Section 68/69A Of The Act, Which Stands Deleted In The Lower Appellate Discussion. This Is What Leaves The Revenue & The Assessee Aggrieved Who Have Filed Their Instant Appeal & Cross Objection; Respectively.

Section 143(2)Section 143(3)Section 68

instant case is whether the Assessing Officer exceeded his jurisdiction in completing the assessment on grounds which were not subject matter of the limited scrutiny. The contention of the learned standing Counsel for the appellant is that the assessee was put on notice on that particular issue by the Assessing ... action of the CIT(A) in confirming the action of the Assessing Officer in making additions in respect of issues not mentioned in limited scrutiny were beyond jurisdiction of the Assessing Officer as the scrutiny assessment was selected for limited scrutiny under Section 143(2) and not complete scrutiny

Sparten Granito Pvt. Ltd, Morvi vs. PCIT Rajkot-1, Rajkot

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

ITA 300/RJT/2024[2018-2019]Status: DisposedITAT Rajkot02 Jun 2025AY 2018-2019

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita No.300/Rjt/2024 Assessment Year: 2018-19 Sparten Granito P. Ltd. Pr.Commissioner Of बनाम S.No.277/ B/H. Siyaram Granito Incometax-1 Jetpur Road, Rangpar Vs. Rajkot. Morbi. Pan : Aaxcs 7650 J (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रतीक"ओरसे/Assessee By : Shri S.N. Soparkar, Sr.Adv-Ar राज"वक"ओरसे/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr सुनवाईक"तार"ख /Date Of Hearing : 03/03/2025 घोषणाक"तार"ख /Date Of Pronouncement : 02/06/2025 Order Per Dr. A. L. Saini, Am: By Way Of This Appeal, The Assessee Has Challenged The Correctness Of The Order Dated 31.03.2024, Passed By The Learned Principal Commissioner Of Income-Tax (In Short “Ld Pcit”) Under Section 263 Of The Income-Tax Act, 1961 (Hereinafter Referred To As 'The Act'), For The Assessment Year 2018-19.Grievances Raised By The Assessee, Which, Being Interconnected, Will Be Taken Up Together, Are As Follows:

For Appellant: Shri S.N. Soparkar, Sr.Adv-ARFor Respondent: Shri Sanjay Punglia, ld.CIT-DR
Section 143(3)Section 263

return of income for assessment year (A.Y.) 2018-19, on 31/10/2018, declaring total income of Rs.NIL. The assessee`s case was selected for limited scrutiny by "CASS" for the following reasons, viz: (1) substantial increase in share capital in a year and (2) Purchases shown in the ITR is less