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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Akhlesh Pandey, Gwalior vs. CIT, Gwalior

The appeal stand allowed in terms of our above order

ITA 13/AGR/2023[2015-16]Status: DisposedITAT Agra22 Apr 2025AY 2015-16

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.13/Agr/2023 (िनधा"रणवष" / Assessment Year: 2015-16) Sh. Akhilesh Pandey Income Tax Officer, बनाम/ 188/189, Line No. 2 Gwalior. Vs. Birla Nagar, Gwalior. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adqpp-7494-Q (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. P.K. Sehgal, Adv. – Ld. Ar " थ"कीओरसे/Respondent By : Sh. Shailender Shrivastava – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 19-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 22.04.2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2015-16 Arises Out Of An Order Of Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [Cit(A)] Dated 30-11-2022 In The Matter Of An Assessment Framed By Ld. Ao U/S 147 R.W.S. 144B Of The Act On 31-03-2022. The Sole Grievance Of The Assessee Is Confirmation Of Addition Of Rs.20.32 Lacs. Having Heard Rival Submissions & Upon Perusal Of Case Records, The Same Is Adjudicated As Under. 2. The Assessee Being Resident Individual Is Stated To Be Engaged In Business In Proprietorship Concern Namely M/S Dhruv Constructions. The Return Of Income Was Scrutinized U/S 143(3) On 31-05-2017 Accepting The Returned Income. However, The Case Was Reopened On The Ground That The Case Was Subjected To Limited Scrutiny. One Of The Issues To Be Examined

For Appellant: Sh. P.K. Sehgal, Adv. – Ld. ARFor Respondent: Sh. Shailender Shrivastava – Ld. Sr. DR
Section 143(3)Section 147Section 148

accepting the returned income. However, the case was reopened on the ground that the case was subjected to limited scrutiny. One of the issues to be examined was to verify the increase in capital. It was noted that the capital of Rs.30.93 Lacs was brought in cash for which

Al-Hamd Agro Food Product Pvt. Ltd., Aligarh vs. PCIT-1, Agra

The appeal stand allowed in terms of our above order

ITA 37/AGR/2021[2016-17]Status: DisposedITAT Agra22 Apr 2025AY 2016-17

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 37/Agr/2021 (िनधा"रणवष" / Assessment Year:2016-17) Al-Hamd Agro Food Product P. Ltd. Pr. Cit - 1 बनाम/ C/O Deepak Singh, Advocate Agra. Vs. 2, Court Of Wards Compound, Aligarh. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafca-0964-R (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Deepak Singh, Adv. – Ld. Ar " थ"कीओरसे/Respondent By : Dr. Arun Kumar Yadav – Ld. Cit-Dr सुनवाईकीतारीख/Date Of Hearing : 19-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 22.04.2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. By Way Of This Appeal, The Assessee Assails Invocation Of Revisionary Jurisdiction U/S 263 By Ld. Pr. Commissioner Of Income Tax-1, Agra (Pr.Cit) For Assessment Year (Ay) 2016-17 Vide Impugned Order Dated 31-03-2021 In The Matter Of An Assessment Framed By Ld. Ao U/S 143(3) Of The Act On 02-11-2016. Having Heard Rival Submissions & Upon Perusal Of Case Records, Our Adjudication Would Be As Under. 2. Upon Perusal Of Case Records, It Could Be Seen That The Assessee’S Case Was Subjected To Limited Scrutiny. During The Course Of Assessment Proceedings, Notices U/S 142(1) Were Issued To The Assessee Calling For Various Details Which Were Duly Been Responded

For Appellant: Sh. Deepak Singh, Adv. – Ld. ARFor Respondent: Dr. Arun Kumar Yadav – Ld. CIT-DR
Section 142(1)Section 143(3)Section 263

adjudication would be as under. 2. Upon perusal of case records, it could be seen that the assessee’s case was subjected to limited scrutiny. During the course of assessment proceedings, notices u/s 142(1) were issued to the assessee calling for various details which were duly been responded ... investigations. Aggrieved, the assessee is in further appeal before us. 4. At the outset, it could be observed that the case was subjected to limited scrutiny and during the course of assessment proceedings, various queries were raised by Ld. AO in this regard. In notice u/s 142(1) dated

Rukmani Devi Jain, Agra vs. Pr.CIT.-1, Agra

The appeals stand allowed in terms of our above order

ITA 30/AGR/2021[2016-17]Status: DisposedITAT Agra22 Apr 2025AY 2016-17

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No. 29/Agr/2021 (िनधा"रणवष" / Assessment Year: 2015-16) & 2. आयकरअपीलसं./ Ita No.30/Agr/2021 (िनधा"रणवष" / Assessment Year: 2016-17) Smt. Rukmani Devi Jain Pr. Cit - 1 बनाम/ 37/396/17, Gopal Kunj Agra. Vs. Agra (Up)-282002. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Anxpj-7557-M (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Deependra Mohan, Ca – Ld. Ar " थ"कीओरसे/Respondent By : Dr. Arun Kumar Yadav – Ld. Cit-Dr सुनवाईकीतारीख/Date Of Hearing : 19-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 22.04.2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. By Way Of These Appeals, The Assessee Assails Revision Of Order U/S 263 For Assessment Years (Ay) 2015-16 & 2016-17. First, We Take Up Appeal For Ay 2015-16 Which Assail Invocation Of Revisionary Jurisdiction U/S 263 By Ld. Pr. Commissioner Of Income Tax-1, Agra (Pr.Cit) Vide Impugned Order Dated 22-03-2021 In The Matter Of An Assessment Framed By Ld. Ao U/S 143(3) Of The Act On 24-12-2017. Having Heard Rival Submissions & Upon Perusal Of Case Records, Our Adjudication Would Be As Under.

For Appellant: Sh. Deependra Mohan, CA – Ld. ARFor Respondent: Dr. Arun Kumar Yadav – Ld. CIT-DR
Section 142(1)Section 143(3)Section 263Section 44A

would be as under. 2. Upon perusal of assessment order, it could be seen that the assessee’s return of income was selected for limited scrutiny to verify whether the cash was deposited from disclosed sources. During the course of assessment proceedings, Ld. AO raised various queries and issued notices

Rukmani Devi Jain, Agra vs. Pr.CIT-1, Agra

The appeals stand allowed in terms of our above order

ITA 29/AGR/2021[2015-16]Status: DisposedITAT Agra22 Apr 2025AY 2015-16

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No. 29/Agr/2021 (िनधा"रणवष" / Assessment Year: 2015-16) & 2. आयकरअपीलसं./ Ita No.30/Agr/2021 (िनधा"रणवष" / Assessment Year: 2016-17) Smt. Rukmani Devi Jain Pr. Cit - 1 बनाम/ 37/396/17, Gopal Kunj Agra. Vs. Agra (Up)-282002. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Anxpj-7557-M (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Deependra Mohan, Ca – Ld. Ar " थ"कीओरसे/Respondent By : Dr. Arun Kumar Yadav – Ld. Cit-Dr सुनवाईकीतारीख/Date Of Hearing : 19-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 22.04.2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. By Way Of These Appeals, The Assessee Assails Revision Of Order U/S 263 For Assessment Years (Ay) 2015-16 & 2016-17. First, We Take Up Appeal For Ay 2015-16 Which Assail Invocation Of Revisionary Jurisdiction U/S 263 By Ld. Pr. Commissioner Of Income Tax-1, Agra (Pr.Cit) Vide Impugned Order Dated 22-03-2021 In The Matter Of An Assessment Framed By Ld. Ao U/S 143(3) Of The Act On 24-12-2017. Having Heard Rival Submissions & Upon Perusal Of Case Records, Our Adjudication Would Be As Under.

For Appellant: Sh. Deependra Mohan, CA – Ld. ARFor Respondent: Dr. Arun Kumar Yadav – Ld. CIT-DR
Section 142(1)Section 143(3)Section 263Section 44A

would be as under. 2. Upon perusal of assessment order, it could be seen that the assessee’s return of income was selected for limited scrutiny to verify whether the cash was deposited from disclosed sources. During the course of assessment proceedings, Ld. AO raised various queries and issued notices

Singur Thana Lspa Co-Operative Marketing Society Ltd, Kolkata vs. ITO, Hooghly

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

ITA 970/KOL/2023[2018-19]Status: DisposedITAT Kolkata21 Apr 2025AY 2018-19

Bench: Shri Rajesh Kumarआयकर अपील सं/Ita No.968-970/Kol/2023 ("नधा"रण वष" / A.Yrs. : 2014-2015, 2017-2018 & 2018-2019) Singur Thana Lspa Vs Ito, Ward-23(2), Hooghly Cooperative Marketing Society Limited, C/O S.N.Ghosh&Associates,Advs 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kolkata-700001 Pan No. :Aabas0029 B (अपीलाथ" /Appellant) (""यथ" / Respondent) .. "नधा"रतीक"ओरसे /Assessee By : Shri Somnath Ghosh & Sarnath Ghosh, Advocates राज"वक"ओरसे /Revenue By : Ms. Madhumita Sas, Addl.Cit सुनवाई क" तार"ख / Date Of Hearing : 17/04/2025 घोषणा क" तार"ख/Date Of Pronouncement : 21/04/2025 आदेश / O R D E R These Are The Appeals Filed By The Assessee Against The Separate Orders All Dated 15.03.2023, Passed By The Ld. Cit(A), National Faceless Appeal Centre, (Nfac), Delhi For The Assessment Year 2014-2015, 2017- 2018 & 2018-2019. 2. As Per The Office Record, It Is Found That All The Three Appeals Of The Assessee Are Filed Belatedly By 120 Days Each. Looking To The Facts & Circumstances Of The Case, We Condone The Delay Of 120 Days Each In Fling All The Three Appeals & The Appeals Are Admitted For Adjudication.

For Appellant: Shri Somnath GhoshFor Respondent: Ms. Madhumita Sas, 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 8. The ld. AR submitted that the notice is not bearing

Singur Thana Lspa Co-Operative Marketing Society Ltd, Kolkata vs. ITO, Hooghly

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

ITA 969/KOL/2023[2017-18]Status: DisposedITAT Kolkata21 Apr 2025AY 2017-18

Bench: Shri Rajesh Kumarआयकर अपील सं/Ita No.968-970/Kol/2023 ("नधा"रण वष" / A.Yrs. : 2014-2015, 2017-2018 & 2018-2019) Singur Thana Lspa Vs Ito, Ward-23(2), Hooghly Cooperative Marketing Society Limited, C/O S.N.Ghosh&Associates,Advs 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kolkata-700001 Pan No. :Aabas0029 B (अपीलाथ" /Appellant) (""यथ" / Respondent) .. "नधा"रतीक"ओरसे /Assessee By : Shri Somnath Ghosh & Sarnath Ghosh, Advocates राज"वक"ओरसे /Revenue By : Ms. Madhumita Sas, Addl.Cit सुनवाई क" तार"ख / Date Of Hearing : 17/04/2025 घोषणा क" तार"ख/Date Of Pronouncement : 21/04/2025 आदेश / O R D E R These Are The Appeals Filed By The Assessee Against The Separate Orders All Dated 15.03.2023, Passed By The Ld. Cit(A), National Faceless Appeal Centre, (Nfac), Delhi For The Assessment Year 2014-2015, 2017- 2018 & 2018-2019. 2. As Per The Office Record, It Is Found That All The Three Appeals Of The Assessee Are Filed Belatedly By 120 Days Each. Looking To The Facts & Circumstances Of The Case, We Condone The Delay Of 120 Days Each In Fling All The Three Appeals & The Appeals Are Admitted For Adjudication.

For Appellant: Shri Somnath GhoshFor Respondent: Ms. Madhumita Sas, 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 8. The ld. AR submitted that the notice is not bearing

Singur Thana Lspa Co-Operative Marketing Society Ltd, Kolkata vs. ITO, Hooghly

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

ITA 968/KOL/2023[2014-15]Status: DisposedITAT Kolkata21 Apr 2025AY 2014-15

Bench: Shri Rajesh Kumarआयकर अपील सं/Ita No.968-970/Kol/2023 ("नधा"रण वष" / A.Yrs. : 2014-2015, 2017-2018 & 2018-2019) Singur Thana Lspa Vs Ito, Ward-23(2), Hooghly Cooperative Marketing Society Limited, C/O S.N.Ghosh&Associates,Advs 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kolkata-700001 Pan No. :Aabas0029 B (अपीलाथ" /Appellant) (""यथ" / Respondent) .. "नधा"रतीक"ओरसे /Assessee By : Shri Somnath Ghosh & Sarnath Ghosh, Advocates राज"वक"ओरसे /Revenue By : Ms. Madhumita Sas, Addl.Cit सुनवाई क" तार"ख / Date Of Hearing : 17/04/2025 घोषणा क" तार"ख/Date Of Pronouncement : 21/04/2025 आदेश / O R D E R These Are The Appeals Filed By The Assessee Against The Separate Orders All Dated 15.03.2023, Passed By The Ld. Cit(A), National Faceless Appeal Centre, (Nfac), Delhi For The Assessment Year 2014-2015, 2017- 2018 & 2018-2019. 2. As Per The Office Record, It Is Found That All The Three Appeals Of The Assessee Are Filed Belatedly By 120 Days Each. Looking To The Facts & Circumstances Of The Case, We Condone The Delay Of 120 Days Each In Fling All The Three Appeals & The Appeals Are Admitted For Adjudication.

For Appellant: Shri Somnath GhoshFor Respondent: Ms. Madhumita Sas, 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 8. The ld. AR submitted that the notice is not bearing

Jayeshkumar Harjani, Panchmahal vs. The ITO, Ward-4(1)(2), Vadodara

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

ITA 2072/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad11 Apr 2025AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/Ita No. 2072/Ahd/2024 निर्धारण वर्ष / Assessment Year : 2017-18 Jayeshkumar Harjani Prop. Of J. P. Enterprise, Municipal Shopping Centre, V/S. B/H. New Bus Stand, At. Po. Godhra, Dist. Panchmahal, Godhra, Gujarat – 389001 Income Tax Officer बनाम/ Ward- 4(1)(2), Vadodara स्थायी लेखा सं./Pan: Acoph2412D अपीलार्थी/ (Appellant) प्रत्यर्थी/ (Respondent) Assessee By: Shri Sunil Maloo, Ar Revenue By : Smt. Mamta Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 09/04/2025 घोषणा की तारीख /Date Of Pronouncement: 11/04/2025 आदेश/Order Per Makarand V. Mahadeokar, Am: This Appeal By The Assessee Is Directed Against The Order Dated 08.10.2024 Passed By The Ld. Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)"], For The Assessment Year 2017-18, Whereby The Ld. Cit(A) Dismissed The Appeal Filed By The Assessee In Limine On The Ground Of Delay.

For Appellant: Shri Sunil Maloo, ARFor Respondent: Smt. Mamta Singh, Sr.DR
Section 143(3)Section 249(2)(c)Section 68Section 69C

filed his return of income for the A.Y. 2017-18 on 05.11.2017 declaring total income of Rs.3,72,030/-. The case was selected for limited scrutiny and assessment was completed u/s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) on 27.12.2019, determining the total