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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

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

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

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

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

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

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

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

Araguntulu Balaramraja Ram Geetha, Rajapalayam vs. Income Tax Officer, Ward 3, Virudhunagar, Income Tax Office

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

ITA 331/CHNY/2025[2018-2019]Status: DisposedITAT Chennai28 Apr 2025AY 2018-2019

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.:331/Chny/2025 िनधा"रण वष" / Assessment Year: 2018-19 Araguntulu Balaramraja Ram The Income Tax Officer, Geetha, Vs. Ward 3, Income Tax Office, No.141, Viruthunagar, Railway Feeder Road, Palayapalayam, Virudhunagar – 626 001. Dharmaraja Big Street, Rajapalayam- 626 117. [Pan: Banpr-3583-H] (""यथ"/Respondent) (अपीलाथ"/Appellant)

For Appellant: Shri. T.Vasudevan, AdvocateFor Respondent: Shri. Keerthi Narayanan, JCIT

Section 144Section 68

Filed her return of income for the assessment year 2018-19 declaring total income of Rs.7,64,410/-. The case was selected for a limited scrutiny for the reason large agricultural income that large agriculture income. Accordingly, statutory notices were issued to the assessee. However, the assessee did not participate

Prathama Constructions, Lucknow vs. ITO-2(2), Lucknow-New, Lucknow

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

ITA 144/LKW/2025[2016-17]Status: DisposedITAT Lucknow25 Apr 2025AY 2016-17

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2016-17 Prathama Constructions V. The Ito-2(2) F-120, Ganj Plaza Lucknow 42, Masjid Lane Hazratganj, Lucknow Tan/Pan:Aakfp8300L (Appellant) (Respondent) Appellant By: None Respondent By: Shri Sunil Kumar Rajwanshi, D.R. Date Of Hearing: 23 04 2025 Date Of Pronouncement: 25 04 2025 O R D E R

For Appellant: NoneFor Respondent: Shri Sunil Kumar Rajwanshi, D.R

Section 142(1)Section 143(3)

income for the year under consideration on 30.07.2016, declaring a total income of Rs.7,56,030/-. The case of the assessee was selected for limited scrutiny under CASS. During the year under consideration, the assessee had shown total turnover at Rs.1,62,62,825/- and income from business at Rs.7

Urmila Mishra, Kanpur vs. ITO, Ward-1(1)(5), Kanpur

In the result, the appeal is partly allowed

ITA 724/LKW/2024[201718]Status: DisposedITAT Lucknow25 Apr 2025

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Urmila Mishra V. The Income Tax Officer E-1/186, Kda Colony Ward 1(1)(5) Dheli Sujanpur, Kanpur Kanpur Tan/Pan:Bndpm1858F (Appellant) (Respondent) Appellant By: Shri Rakesh Garg, Advocate Respondent By: Shri Sanjeev Krishna Sharma, D.R. Date Of Hearing: 29 01 2025 Date Of Pronouncement: 25 04 2025 O R D E R

For Appellant: Shri Rakesh Garg, AdvocateFor Respondent: Shri Sanjeev Krishna Sharma, D.R

Section 115BSection 143(1)Section 271ASection 69A

initially processing of the return under section 143(1) of the Income Tax Act, 1961 (hereinafter called “the Act’), the case was selected for Limited Scrutiny through CASS for the reason of – (1) large investment in property and (2) large value of cash deposits during the demonetization period. ITA No.724/LKW/2024

Shivam Developers, Ahmedabad vs. The Dy.CIT, Circle-3(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 2092/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2016-17

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.2092/Ahd/2024 िनधा"रण वष" /Assessment Year : 2016-17 Shivam Developers The Dy.Cit बनाम/ 1, Shivam Monreve Bungalows Circle-3(1)(1) V/S. Opp. Baabul Baag Party Plot Ahmedabad Sindhu Bhavan Road Bodakdev, Ahmedabad–380 054 "थायी लेखा सं./Pan:Abvfs 1174 R (अपीलाथ'/ Appellant) ("( यथ'/ Respondent) Assessee By : Shri S.N. Soparkar, Sr. Advocate & Shri Parin Shah, Ar Revenue By : Shri B.P. Srivastava, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 16/04/2025 घोषणा की तारीख /Date Of Pronouncement: 25/04/2025 आदेश/O R D E R Per Narendra Prasad Sinha, Am: This Appeal By The Assessee Is Directed Against The Order Dated 01.11.2024 Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As ‘Cit(A)’], For The Assessment Year (Ay) 2016-17, Arising From The Assessment Order Dated 23.03.2022 Passed Under Section 147 R.W.S.144B Of The Income Tax Act, 1961 [Hereinafter Referred To As ‘The Act’] By The Assessing Officer [Hereinafter Referred To As ‘Ao’]. Shivam Developers Vs. Dy.Cit, Cir-3(1)(1) Asst. Year : 2016-17 2

For Appellant: Shri S.N. Soparkar, Sr. advocate and Shri Parin Shah, ARFor Respondent: Shri B.P. Srivastava, Sr.DR

Section 143(3)Section 147

erred in law and on facts in upholding the reopening of the case u/s.147 without any fresh information, when the required information under limited scrutiny is furnished and duly verified by the predecessor Assessing Officer. 2. Ld. CIT(A) has erred in law and on facts in upholding the addition

Satnam Singh, Nai Basti Aligarh vs. Income Tax Officer Ward 4(1)(1), Marris Road Aligarh

In the result, the appeal is allowed for statistical purposes

ITA 12/AGR/2025[2016-17]Status: DisposedITAT Agra24 Apr 2025AY 2016-17

Bench: Learned Cit(A), Who Dismissed Assessee’S First Appeal Exparte In Default Of Assessee.

Section 143(1)Section 143(2)Section 144Section 250Section 250(6)

total income of Rs. 8,44,930/-. The return was processed u/s. 143(1) of the Act. Later on the case was selected for limited scrutiny under computer aided scrutiny selection (CASS). Statutory notices u/s 143(2) and 142(1) were issued and served upon the assessee. But the assessee

Labhuben Manubhai Mangukiya, Surat vs. Income Tax Officer Ward 3(3)(5), Surat

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

ITA 773/SRT/2024[2017-18]Status: DisposedITAT Surat24 Apr 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.773/Srt/2024 Assessment Year: (2017-18) (Physical Hearing) Labhuben Manubhai Mangukiya. Vs. The Ito, 24, Ramkrishna Society, L.H. Road, Ward-3(3)(5), Surat - 395006 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aczpm1695G (Appellant) (Respondent)

Section 115BSection 143(2)Section 250Section 253(3)Section 68

income on 22.02.2018 for AY.2017-18, declaring total income of Rs.2,03,220/- and agricultural income of Rs.86,300/-. The case was selected for limited scrutiny on the issue of “Large value cash deposits during demonetization period as compared to returned income”. Various notices u/s 143(2), 142(1) and show

Pratima Panwar, Jaipur vs. I.T.O, Ward 3(3), Jaipur

In the result, the appeal of the assessee is allowed

ITA 218/JPR/2025[A.Y 2017-18]Status: DisposedITAT Jaipur24 Apr 2025

Bench: Him.

For Appellant: Sh. G. M. Mehta, C.AFor Respondent: Sh. Gautam Singh Choudhary, JCIT

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

return of income on 13.02.2018 declaring total income of Rs. 6,60,000/-. b) The case of the assessee was selected for Limited scrutiny and statutory notices were issued from time to time. c) On the given dates assessee has furnished her reply on ITBA along with submission of copy

Sanjaymama Vitthalrao Shinde, Pune vs. DCIT Circle 12, Pune

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

ITA 467/PUN/2025[2018-19]Status: DisposedITAT Pune24 Apr 2025AY 2018-19

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2018-19

For Appellant: Shri Pramod S ShingteFor Respondent: Shri Milind Debaje – JCIT (Virtual)

Section 143(2)Section 143(3)Section 270A(1)Section 57

individual and filed his return of income on 30.10.2018 declaring total income of Rs.89,40,630/-. The case 2 was selected for limited scrutiny assessment under the E-assessment Scheme, 2019 on the following issues: “S.No. Issues i. Deductions from Income from Other Sources” 4. Accordingly statutory notices

M/S. Shanti Vyapar Pvt. Ltd., Kolkata vs. ITO, Ward 9(1), Kolkata

ITA 299/KOL/2025[2014-15]Status: DisposedITAT Kolkata24 Apr 2025AY 2014-15

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri Saumitra Choudhury, ARFor Respondent: Shri Sailen Samadder, DR

Section 142(1)Section 143(2)Section 143(3)Section 56(2)

raised a legal issue challenging the assessment framed by the Id. AO on the ground that the case of the assessee was selected for limited scrutiny however, the scrutiny proceedings were conducted as if this was a complete unlimited scrutiny and therefore, the assessment was framed is invalid ... that the assessee filed the return of income on 30.12.2014 declaring total income at ₹44,840/-. The case of the assessee was selected for limited scrutiny under Computer Assisted Page 2 ITA No.299/KOL/2025 M/s Shanti Vyapar Pvt. ltd; A.Y. 2014-15 Scrutiny Selection (CASS) and accordingly, the statutory notices were

ACIT, Kolkata vs. Subhas Kumar Kedia, Kolkata

The appeal of the Revenue is dismissed

ITA 1648/KOL/2024[2017-18]Status: DisposedITAT Kolkata24 Apr 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Ms. Shreya Loyalka, ARFor Respondent: Shri Arup Chatterjee, DR

Section 143(1)Section 245D(4)Section 68

income at %1,21,90,090/-, which was duly processed u/s 143(1) of the Act. The case of the assessee was selected for limited scrutiny to examine the cash deposit into the bank account during the year. Accordingly, the statutory notices along with questionnaire were issued and served upon

Basudeb Das, South 24 Parganas vs. I.T.O., Ward - 26(1), Kolkata

In the result, appeal of the assessee is allowed

ITA 1308/KOL/2024[2017-2018]Status: DisposedITAT Kolkata24 Apr 2025AY 2017-2018

Bench: Shri Rajesh Kumarआयकर अपील सं/Ita No.1308/Kol/2024 (नििाारण वर्ा / Assessment Years : 2017-2018) Basudeb Das, Vs Ito, Ward-26(1), Kolkata Mamudpur, Charashyamdas, Bishnupur, South 24 Parganas West Bengal Pan No. :Aqppd9974P (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररतीकीओरसे /Assessee By : Shri Soumitra Choudhury, Advocate राजस्वकीओरसे /Revenue By : Ms. Madhumita Das, Addl.Cit सुनवाई की तारीख / Date Of Hearing : 17/04/2025 घोषणा की तारीख/Date Of Pronouncement : 24/04/2025 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Order Dated 09.03.2024, Passed By The Ld. Cit(A), National Faceless Appeal Centre, (Nfac), Delhi For The Assessment Year 2017-2018. 2. As Per The Appeal Record, It Is Observed That The Appeal Is Filed Belatedly By 34 Days. In This Regard, The Assessee Has Filed Condonation Application Stating Therein Sufficient Reasons For Condonation Of Delay. Considering The Reasons Stated In The Application Of The Assessee, The Delay Of 34 Days In Filing The Present Appeal Is Condoned & The Appeals Is Admitted For Hearing. 3. At The Time Of Hearing, Ld. Counsel Of The Assessee Has Raised The Additional Ground Which Is Extracted As Under :- 1. For That On The Facts Of The Case, The Assessing Officer Issuing The Notice U/S. 143(2) Of The I.T. Act, 1961 On 24.09.2018 Did Not Have Jurisdiction Over The Case Of The Assessee, As There Was No Mention Of The Type Of Scrutiny Under Which The Case Of The Assessee Has Been Selected, Hence The Notice Is Bad-In-Law

For Appellant: Shri Soumitra Choudhury, AdvocateFor Respondent: Ms. Madhumita Das, Addl.CIT

Section 143(2)Section 143(3)

been provided that w.e.f. 23.06.2017, the notice u/s.143(2) of the Act to be issued in any of the three following forms :- ❖ Limited Scrutiny (Computer Aided Scrutiny Selection ❖ Complete Scrutiny (Computer Aided Scrutiny Selection) ❖ Compulsory Manual Scrutiny 6. The ld. AR submitted that the notice is not bearing

Jitendra Virendra Bagrecha, Navi Mumbai vs. Income Tax Officer, Navi Mumbai

In the result the appeal filed by the assessee stands partly allowed for statistical purpose

ITA 1140/MUM/2025[2017-18]Status: DisposedITAT Mumbai24 Apr 2025AY 2017-18

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 143(3)Section 250Section 250(2)Section 44ASection 45Section 54Section 69A

appeal on merits and erred in ignoring the submissions and exhaustive documents filed on set- aside assessment record; 4. The JAO has exceeded the limited scrutiny proceeding and without obtaining prior approval from higher authority, hence, the Assessment order u/s 143(3) is bad in law. a. On the facts

Ranee Narah, Guwahati vs. Assistant Commissioner of Income Tax, Circle-3, Guwahati

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

ITA 84/GTY/2020[2016-17]Status: DisposedITAT Guwahati23 Apr 2025AY 2016-17

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 143(3)Section 234ASection 234BSection 234CSection 250Section 68Section 69

correct facts and findings and is erroneous on points of law. 2. For that the learned Assessing Officer is not justified in converting the limited scrutiny case into complete scrutiny case without any approval of higher authority as per provision of the Act and Learned CIT Appeals also erred

Jashubhai Manjibhai Patel, Surat vs. ITO, Ward-1, Bardoli

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

ITA 845/SRT/2024[2017-18]Status: DisposedITAT Surat23 Apr 2025AY 2017-18

Bench: Shri Bijayananda Pruseth & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.845/Srt/2024 Assessment Year: (2017-18) (Hybrid Hearing) Jashubhai Manjibhai Patel, Vs. The Ito, 84, Sainath Society, At-Maandavi Ward - 1, Ta-Mandavi, Surat-394160 Bardoli "थायीलेखासं./जीआइआरसं./Pan/Gir No: Amppp2266C (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Ms. Dalzin Madan, Ca Respondent By Shri Mukesh Jain, Sr.Dr Date Of Hearing 05/02/2025 Date Of Pronouncement 23/04/2025

Section 115BSection 143(2)Section 250Section 253Section 253(3)Section 271A

addition on issue other than the issue mentioned in the notice u/s 143(2) where the case of the assessee has been selected for limited scrutiny. 2. On the facts and circumstances of the case as well as law on the subject, the learned CIT(A) has erred in confirming ... return of income on 27.03.2018 for AY.2017-18, declaring total income of Rs.3,25,840/-. The case ITA No.845/SRT/2024/AY.2017-18 Jashubhai M Patel was selected for limited scrutiny. Accordingly, notices u/s 143(2) and u/s 142(1) were issued and served upon the assessee. In response, the assessee submitted copy of 7/12

Antpara Samabay Krishi Unayan Samity Limited, Antpara, Burdwan vs. ACIT, NFAC, Delhi/ ITO, Ward - 1(1), Burdwan

In the result, all the captioned appeals of the assessee are allowed

ITA 2053/KOL/2024[2020-2021]Status: DisposedITAT Kolkata23 Apr 2025AY 2020-2021

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma

Section 143(2)Section 250Section 80PSection 80P(2)(a)

case of the assessee was selected for scrutiny assessment followed by notices issued u/s 143(2) and 142(1) of the Act. The limited scrutiny assessment was carried out in respect of following issues: a. bonus or commission to employee b. investments/advances/loans c. deduction from total income under Chapter ... Samabay Krishi Unayan Samity Ltd 9. The ld. AR in the above issue stated that while the case of the assessee was selected for limited scrutiny only in respect of three issues i.e. bonus or commission to employee, investments/advances/loans & deduction from total income under Chapter VI-A. However, the specific

Antpara Samabay Krishi Unayan Samity Limited, Antpara vs. ACIT, NFAC, Delhi

In the result, all the captioned appeals of the assessee are allowed

ITA 1635/KOL/2024[2018-19]Status: DisposedITAT Kolkata23 Apr 2025AY 2018-19

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma

Section 143(2)Section 250Section 80PSection 80P(2)(a)

Antpara Samabay Krishi Unnayan Samity Limited, Antpara vs. I.T.O., Ward 1(1), Burdwan, Aaykar Bhawan

In the result, all the captioned appeals of the assessee are allowed

ITA 1634/KOL/2024[2017-18]Status: DisposedITAT Kolkata23 Apr 2025AY 2017-18

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma

Section 143(2)Section 250Section 80PSection 80P(2)(a)

Antpara Samabay Krishi Unnayan Samity Limited, Antpara vs. ITO Ward 1(1), Burdwan

In the result, all the captioned appeals of the assessee are allowed

ITA 1632/KOL/2024[2013-14]Status: DisposedITAT Kolkata23 Apr 2025AY 2013-14

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma

Section 143(2)Section 250Section 80PSection 80P(2)(a)

Mr.Jayaram Subramanaiam, Chennai vs. DCIT, Central Circle-2(1), Chennai

In the result, the appeal of the assessee is dismissed

ITA 26/CHNY/2025[2018-19]Status: DisposedITAT Chennai23 Apr 2025AY 2018-19

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.26/Chny/2025 Assessment Years: 2018-19 Mr.Jayaram Subramaniam, The Deputy Commissioner Of No.9A Nn Laxmi Street, Income Tax, Valasaravakkam, Central Circle-2(1), Aswathy, Chennai Chennai- 600 087. [Pan: Afaps5678H] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Ms.Lavanya, Ca प्रत्यर्थी की ओर से /Revenue By : Smt.Samantha Mullamudi, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 24.03.2025 घोषणा की तारीख /Date Of Pronouncement : 23.04.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Ms.Lavanya, CAFor Respondent: Smt.Samantha Mullamudi, Addl.CIT

Section 143(1)Section 143(3)

made no adverse findings in the order u/s. 143(3) of the Act dated Page - 3 - of 7 20.02.2020 and has completed the Limited Scrutiny assessment proceedings by accepting the return of income for the AY-2018-19, there can be no ground on the part of the appellant

Poonam Saxena, Aligarh vs. ITO, Ward 4(1)(5), Aligarh

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

ITA 34/AGR/2024[2017-18]Status: DisposedITAT Agra22 Apr 2025AY 2017-18

Bench: Shri Sunil Kumar Singh & Shri Brajesh Kumar Singh[Assessment Year: 2017-18]

Section 142(1)Section 143(2)Section 143(3)Section 144Section 69A

both the sides and on the basis of material available on record. 3. Brief facts of the case:-This case was picked up for limited scrutiny under Computer Access Selection of Scrutiny (CASS) to verify the large cash deposited during the demonetization period. The Assessing Officer noted that the assessee ... income at Rs. 3,14,410/- only. Subsequently, to verify the large cash deposits during the demonetization period; the case was picked-up for Limited Scrutiny under Computer Access Selection of Scrutiny (CASS). Therefore, notice u/s 143(2) of Income- tax Act, 1961 was issued on 09/08/2018 fixing