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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Surendranagar District Co Op Producers Union Limited, Surendranagar vs. Assistant Commissioner of Income Tax, Surendranagar Circle

In the result, appeal filed by the assessee is allowed

ITA 429/RJT/2025[2014-15]Status: DisposedITAT Rajkot10 Feb 2026AY 2014-15

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 429/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2014-15) Surendranagar District Co. Op. Acit, Circle, Producers Union Ltd. Vs. Surendranagar-363035 Plot No.249, Phase 2 Gidc Market Yard Circle, Sursagar Dairy, Wadhwan Road, Surendranagar-363035 (Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaas8375B (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Kalpesh Doshi, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : Heard On 09/10/2025, Refixed For Clarification On 03.11.2025 & Finally Heard On 02.02.2026 : 10/02/2026 Date Of Pronouncement Order Per, Dr. Arjun Lal Saini, A.M.:

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 234ASection 250Section 271(1)(c)Section 80P(2)(b)Section 80P(2)(d)

eligible for deduction under section 80P(2)(d) of the Act. 25. We note that the assessee’s case was selected for limited scrutiny to examine investments, advances, loans, unsecured loans, deduction from total income under Chapter VI-A of the Act. The findings of the Assessing Officer under section ... reproduced below: “1. The case was selected for Limited Scrutiny assessment under the E-assessment Scheme, 2019 on the following issues: S. No. Issues i. Investments/Advances/Loans ii. Unsecured Loans iii. Deduction from Total Income under Chapter VI-A The assessee society has filed Return of Income for AY.2018-19

Late Shri Anand Alias Vishwanath Mamani, Through His Legal Heir Smt. Ratna Anand Mamani, Belagavi vs. The Income Tax Officer, Ward -1 Belagavi, Belagavi

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

ITA 352/PAN/2025[2017-18]Status: DisposedITAT Panaji04 Feb 2026AY 2017-18

Bench: Shri Pavan Kumar Gadalei T A. No.352/Pan/2025 (A.Y. 2017-18) Late Shri Anand Alias Vs Ito-Ward-1, Vishwanath Mamani Through Feroj Khimjibhai Cpx, . His Legal Heir Smt.Ratna Civil Hospital Road Anand Mamani, Belagavi-590001. 3138/3, Ramapur Site, Karnataka. Saundatti, Belagavi-591126, Karnataka. Pan,No.Avhpm6615P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Sri.Shivananad Halbhavi.Ar Revenue By Smt.Rijula Uniyal.Sr.Dr सुनवाई की तारीख/Date Of Hearing 03.02.2026 घोषणा की तारीख/Date Of Pronouncement 04.02.2026 Order Per Pavan Kumar Gadale ,Jm: The Assesse Has Filed The Appeal Against The Order Of The Nfac/Cit(A) Passed U/Sec143(3) & U/Sec 250 Of The Act. The Assesee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Addition Of Unexplained Cash Deposits Under Section 68 Of The Act Made By The Assessing Officer. 2. The Brief Facts Of The Case Are That, The Assesse Has Filed The Return Of Income For A.Y.2017-18 On 05.08.2017 Disclosing A Total Income Of Rs.11,93,580/- & The Case

Section 68

Rs.11,93,580/- and the case 2 ITA. No.352/PAN/2025 Anand Alias Vishwanath Mamani through legal heir smt Ratna Anand Mamani.. was selected for limited scrutiny under the CASS to verify (i)Large cash deposits during the year compared to returned income(ii)Cash deposit during demonetization period