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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Sita Rama Raju Sagi, Bhimavaram vs. ITO Ward 1 Bhimavaram, Bhimavaram

In the result, appeal of the assessee is allowed

ITA 154/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam20 May 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No.154/Viz/2025 (धनिाारण िर्ा / Assessment Year : 2020-21) Sita Rama Raju Sagi, Vs. Income Tax Officer, Bhimavaram – 534202. Ward-1, Pan: Egapa3925J Bhimavaram. (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलार्थी की ओर से/ Assessee By : Mrs. Hema Latha K, Ca प्रत्यार्थी की ओर से / Revenue By : Dr. Satyasai Rath, Cit-Dr सुनिाई की तारीख / Date Of Hearing : 30/04/2025 घोर्णा की तारीख/Date Of : 20/05/2025 Pronouncement O R D E R

For Appellant: Mrs. Hema Latha K, CAFor Respondent: Dr. Satyasai Rath, CIT-DR
Section 143(2)Section 143(3)Section 263Section 44A

income on 31/03/2021 for the AY 2020-21 admitting a total income of Rs. 6,61,470/-. Subsequently, the case was selected for limited scrutiny through CASS and notices U/s. 143(2) and 142(1) of the Act were issued from time to time. Considering the submissions furnished ... benefit of carry forward loss of income from house property. On this issue, the Ld. AR submitted that the case was selected for limited scrutiny for the purpose of verification of income from house property and the Ld. AO has verified the submissions made by the assessee during the assessment

Anil Shrichand Sadhwani, Nashik vs. ITO, Ward 2(1), Nashik

Appeal is allowed

ITA 2443/PUN/2024[2015-16]Status: DisposedITAT Pune20 May 2025AY 2015-16

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2443/Pun/2024 िनधा"रण वष" / Assessment Year: 2015-16 Anil Shrichand Sadhwani, V The Income Tax Officer, Chhatrapati Shivaji Hsg Soc, S Ward-2(1), Pune. Nashik Road, Jailroad, Nashik – 422101. Maharashtra. Pan: Annps1615D Appellant/ Assessee Respondent / Revenue Assessee By Shri Sanket M Joshi – Ar Revenue By Shri Ramnath P Murkunde – Dr Date Of Hearing 23/04/2025 Date Of Pronouncement 20/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: Thisappeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250Of The Income Tax Act, 1961; Dated 23.09.2024 For Assessment Year 2015-16. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Learned Ctt(A) Erred In Confirming The Addition U/S 50C Of Rs.6,15,600 By Taxing The Appellant'S Share In Difference Between Govt. Valuation Of Rs.2,52,31,000 & Actual Consideration Of Rs 2,40,00,000 Received On Sale Of Immovable Property As Income U/S 50C Without

Section 143(3)Section 250oSection 263Section 50CSection 54ESection 54F

appeal : 2. Assessee is an Individual who filed Return of Income for A.Y.2015-16 on 30.09.2015. The assessee’s Return of Income was selected for limited scrutiny on the ground to verify Assessee’s sale consideration, claim of deductions, turnover etc. The Assessing Officer passed the original assessment order under section

Bhupesh Ravinder Datt Sharma, Australia vs. ITO, Ward- 2(85), Delhi

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

ITA 1306/DEL/2025[2016-17]Status: DisposedITAT Delhi20 May 2025AY 2016-17

Bench: Shri Vikas Awasthyआअसं.1306/िद"ी/2025(िन.व. 2016-17) Bhupesh Ravinder Datt Sharma, 16A, Fisher Street, Victoria, Australia 314500 ...... अपीलाथ"/Appellant Pan: Augps-4400-A बनाम Vs. Income Tax Officer, Ward-28(5), ..... "ितवादी/Respondent Civic Centre, Minto Road, New Delhi 110002 अपीलाथ" "ारा/ Appellant By : None "ितवादी"ारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 20/05/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 20/05/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (Hereinafter Referred To As 'The Cit(A)') Dated 19.12.2024, For Assessment Year 2016-17. 2. The Brief Facts Of The Case As Emanating From Records Are: The Assessee Filed Return Of Income U/S. 139 Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’) For Impugned Assessment Year Declaring Total Income Of Rs.8,11,370/-. The Return Of The Assessee Was Selected For Limited Scrutiny, Notice U/S. 143(2) Of The Act Dated 14.07.2017 Was Issued To The Assessee. Despite Service Of Aforesaid Notice, The Assessee Failed To Respond To The Same. The Assessing Officer (Ao)

For Appellant: NoneFor Respondent: Shri Manoj Kumar, Sr. DR
Section 139Section 143(2)Section 144Section 5Section 68

referred to as ‘the Act’) for impugned assessment year declaring total income of Rs.8,11,370/-. The return of the assessee was selected for limited scrutiny, notice u/s. 143(2) of the Act dated 14.07.2017 was issued to the assessee. Despite service of aforesaid notice, the assessee failed to respond

Meditation Properties Pvt Ltd, New Delhi vs. ITO Ward-16(3), New Delhi

In the result, impugned order is set aside and appeal of the assessee is allowed

ITA 9394/DEL/2019[2015-16]Status: DisposedITAT Delhi19 May 2025AY 2015-16

Bench: Shri Vikas Awasthyआअसं.9394/िद"ी/2019(िन.व. 2015-16) Meditation Properties P. Ltd., Flat No. 10, C-1/2, Model Town, New Delhi 110009 ...... अपीलाथ"/Appellant Pan: Aaacm-1194-N बनाम Vs. Assistant Commissioner Of Income Tax, Appeal-6, Laxmi Nagar, District Centre, ..... "ितवादी/Respondent New Delhi 110092 अपीलाथ" "ारा/ Appellant By : Shri Parveen Kumar, Executive Employee "ितवादी"ारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 19/05/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 19/05/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-6, Delhi (Hereinafter Referred To As 'The Cit(A)') Dated 27.09.2019, For Assessment Year 2015-16. 2. Shri Parveen Kumar, Appearing On Behalf Of The Assessee Submits That The Short Issue In Appeal Is That The Case Of Assessee Was Selected For Limited Scrutiny For The Following Reasons: “(I) There Is A Large Difference In The Opening Stock Of The Current Year & The Closing Stock Of Previous Year In P&L Account As Per Return Of Income; &

For Appellant: Shri Parveen Kumar, Executive EmployeeFor Respondent: Shri Manoj Kumar, Sr. DR
Section 143(2)

Parveen Kumar, appearing on behalf of the assessee submits that the short issue in appeal is that the case of assessee was selected for limited scrutiny for the following reasons: “(i) There is a large difference in the opening stock of the current year and the closing stock of previous ... addition of Rs.20,19,990/-. He submitted that without approval from Competent Authority, the AO could not have travelled beyond the scope of limited scrutiny. 3. Per contra, Shri Manoj Kumar representing the department vehemently defended the impugned order and prayed for dismissing appeal of the assessee

Fazal Husain, Nand Nagri vs. ITO, Delhi

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

ITA 5633/DEL/2024[2017-2018]Status: DisposedITAT Delhi16 May 2025AY 2017-2018

Bench: Shri Shamim Yahya & Shri Vimal Kumarassessment Year: 2017-18 Fazal Husain, Vs Ito, E-1/424, Nand Nagri, Ward 59(7), Delhi – 110 093. Delhi. Pan: Absph4524R (Appellant) (Respondent) Assessee By : Shri Fazal Husain (Assessee In Person) Revenue By : Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing : 05.05.2025 Date Of Pronouncement : 16.05.2025 Order Per Vimal Kumar, Jm: This Appeal By The Appellant Assessee Is Against The Order Dated 07.10.2024 Of The Ld. Commissioner Of Income-Tax (Appeals), Nfac, Delhi [Hereinafter Referred To As ‘The Ld. Cit(A)’] U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) In Appeal Arising Out Of The Order Dated 09.12.2019 U/S 143(1) Of The Act Of The Ito, Ward-59(7), Delhi (Hereinafter Referred To As ‘The Ld. Ao’), For Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee E-Filed The Return Of Income On 09.02.2018 Declaring An Income Of Rs.3,81,580/-. The Case Was Selected For Limited Scrutiny Under Cass For The Reason Of Verifying The Cash Deposit During The Demonetization Period. Notice U/S 143(2) Of The Act Was Issued. Notices U/S 142(1) Of The Act Along With Questionnaire Were Issued To The Assessee To Draw Details. However, The Assessee Did Not File Any Reply. As Per Sft Reported, The Assessee Deposited A Cash Of Rs.58,80,600/- In His Bank Account During The Demonetization Period, I.E., From 09.11.2016 To 31.12.2016. The Appellant- Assessee Was Given Final Show Cause Notice Dated 03.12.2019. The Assessee Neither Appeared Nor Filed Any Documents. On Completion Of Proceedings, The Ld. Ao, Vide Order Dated 9Th December, 2019, Made Additions Of Rs.58,80,600/- & Rs.1,48,500. Against This Order Dated 09.12.2019, The Appellant Assessee Filed Appeal Before The Ld.Cit(A), Which Was Dismissed.

For Appellant: Shri Fazal Husain (Assessee in person)For Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 142(1)Section 143(1)Section 143(2)Section 250

that the assessee e-filed the return of income on 09.02.2018 declaring an income of Rs.3,81,580/-. The case was selected for limited scrutiny under CASS for the reason of verifying the cash deposit during the demonetization period. Notice u/s 143(2) of the Act was issued. Notices