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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Rajendran Sharmila, Annur vs. Commissioner of Income Tax Appeals, Delhi

In the result, appeal of the assessee is allowed

ITA 2315/CHNY/2025[2017-2018]Status: DisposedITAT Chennai16 Feb 2026AY 2017-2018

Bench: Shri Manu Kumar Giri & Shris.R.Raghunathaआयकर अपीलसं./Ita No 2315/Chny/2025 निर्धारणवर्ष/Assessment Year: 2017-18 Rajendran Sharmila 1/66 Main Road, Kariagoundanur Vadakkalur Post, Coimbatore, Tamil Nadu-641653 (अपीलार्थी/Appellant) V. Ito Non Corporate Ward 3(2), Све (प्रत्यर्थी/Respondent) [Pan: Bicps 3272 D] अपीलार्थीकी ओरसे/ Assessee By Mr. K. Muthukumar, Ca प्रत्यर्थीकी ओरसे / Respondent By Mr. C. Sivakumar, Addl.Cit सुनवाईकीतारीख/Date Of Hearing 08.01.2026 घोषणाकीतारीख / Date Of 16.02.2026 Pronouncement आदेश / Order Per Manu Kumar Giri, Jm: This Appeal By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals) [Cit(A)] Dated 07.07.2025 For The Assessment Year 2017-18, Confirming The Addition Of Rs.70,50,000/- Made By The Ao U/S. 69A Of The Income Tax Act, 1961 (“The Act”).

Section 142(1)Section 143(2)Section 143(3)Section 69A

that the assessee filed his Return of Income on 20.09.2017 declaring a total income of Rs.7,24,610/-. Subsequently, the case was selected for Limited Scrutiny under the Computer Assisted Scrutiny Selection (CASS) mechanism. The specific reason for such selection was verification of “cash deposits during the year

M/S Shivansh Infraestate Pvt.Ltd., Lucknow vs. Dy. CIT Range-6, Lucknow

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

ITA 106/LKW/2024[2015-16]Status: DisposedITAT Lucknow13 Feb 2026AY 2015-16

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2015-16 M/S Shivansh Infraestate Pvt. Ltd., Vs. The Deputy Commissioner Of 3Rd Floor, Block-A, Surajdeep Income Tax, Range-6, 3Rd Floor, Complex, 1-Jopling Road, 27/2, Raja Ram Mohan Rai Marg, Lucknow-226001 P.K. Complex, Lucknow Pan: Aaqcs5896P (Appellant) (Respondent) Assessee By: Sh. Shubham Rastogi, C.A. Revenue By: Sh. Neeraj Kumar, Cit Dr Date Of Hearing: 20.11.2025 Date Of Pronouncement: 13.02.2026 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac Passed Under Section 250 Of The Income Tax Act, 1961 On 18.01.2024 Wherein The Ld. Cit(A) Has Partly Allowed The Appeals Of The Assessee Against The Orders Of The Ld. Assessing Officer Dated 30.12.2017. The Grounds Of Appeal Are As Under:- “1- The Ld. Cit (A) Nfac Erred On Facts & In Law In Dismissing The Ground That Notice U/S 143(2) Was Issued By Ito-6(1) Lucknow On 01.04.2016 Without Appreciating That Jurisdiction Of Case Lies With Dcit, Range-6, Lucknow, Hence The Notice Issued By Ito-6(1) Is Without Jurisdiction & Invalid. Further, No Notice U/S 143(2) Has Been Issued By Jurisdictional Dcit, Range-Vi, Lucknow Within The Period As Per Section 143(2) Of L. T. Act. Hence The Present Assessment Is Invalid, Bad In Law & Liable To Be Quashed. 2- The Ld. C.I.T. (A) Upheld The Addition Without Appreciating That Ld. A. O. Rejected The Books Of Account & Instead Of Estimating The Net Profit, Additions Were Made On The Basis Of Same Books Of Account By Disallowing Expenses Under Different Heads Total Rs. 1,75,91,607/- & Addition U/S 68 R. W. S. 115Bbe Of I. T. Act For Rs. 1,32,78,833/- Which Is Contrary To The Provisions Of Law.

For Appellant: Sh. Shubham Rastogi, C.AFor Respondent: Sh. Neeraj Kumar, CIT DR
Section 143(2)Section 145(3)Section 250Section 68

also challenged the covering of the entire gamut of assessment during the assessment proceedings pointing out that the case had been selected for limited scrutiny, but the ld. CIT(A) held the same to be untenable in view of the fact that it was mentioned in the assessment order that

Guhana Educational Society, Suryapet vs. ITO, Exemption Ward-1(2), Hyderabad

In the result, the appeal of the assessee is partly allowed

ITA 784/HYD/2025[2017-18]Status: DisposedITAT Hyderabad11 Feb 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.784/Hyd/2025 ("नधा"रण वष"/Assessment Year: 2017-18) Guhana Educational Society Vs. Income Tax Officer 2-1-65, Kasturi Bazar Exemption Ward-1(2) Suryapet-508213 Aayakar Bhavan Telangana Basheerbagh, Hyderabad Telangana Pan: Aaaag5294R (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "वारा/Revenue By:: Dr. Sachin Kumar, Sr-Dr सुनवाई क" तार"ख/Date Of Hearing: 29/01/2026 घोषणा क" तार"ख/Pronouncement: 11/02/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Guhana Educational Society (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Addl/Jcit(A)-3, Mumbai (“Ld. First Appellate Authority”) Dated 13.03.2025 For The A.Y.2017-18. 2. Assessee Has Raised The Following Grounds Of Appeal: “1. The Order Of The Learned Cit (A) Is Erroneous Both On Facts & In Law; 2. The Learned Cit (A) Erred In Confirming The Action Of The Assessing Officer In Rejecting The Books Of Account & In Resorting To Estimation Of Income At 8% Of The Receipts Of Rs.2,58,90,677/-;

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: : Dr. Sachin Kumar, SR-DR
Section 10Section 12ASection 143(3)

after claiming exemption under section 10(23C)(iiiab) of the Income Tax Act, 1961 (“the Act”). The case of the assessee was selected for limited scrutiny through CASS, and accordingly, notices under sections 143(2) and 142(1) of the Act were issued by the Learned Assessing Officer