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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Income Tax Officer, Aayakar Bhawan Poorva Kol vs. Sita Ram Pareek, Burrabazar

In the result, the appeal of the assessee is allowed, whereas, the appeal of the revenue is dismissed

ITA 653/KOL/2024[2017-18]Status: DisposedITAT Kolkata11 Mar 2025AY 2017-18

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyi.T.A. No.378/Kol/2024 Assessment Year: 2017-18 Sitaram Pareek………………....…………...………......................……….……Appellant Ca Anup Kumar Sanghai Sanghai & Co, Ca 21, Hemanta Basu Sarani, 2Nd Floor, Room No.204, Kolkata -1. [Pan:Alqpp5688N] Vs. Ito, Ward-36(1), Kolkata..............…..….…..….........……........……...…..…..Respondent I.T.A. No.653/Kol/2024 Assessment Year: 2017-18 Ito, Ward-36(1), Kolkata ………………....………......................……….……Appellant Vs. Sitaram Pareek..............…..….…..…..........................……........……...…..…..Respondent Ca Anup Kumar Sanghai Sanghai & Co, Ca 21, Hemanta Basu Sarani, 2Nd Floor, Room No.204, Kolkata -1. [Pan:Alqpp5688N] Appearances By: Shri Anup Sanghai, Fca, Appeared On Behalf Of The Appellant. Shri Abhijit Adhikari, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : March 10, 2025 Date Of Pronouncing The Order : March 11, 2025 Order Per Rajesh Kumar: The Captioned Are Cross-Appeals, One By The Assessee & The Other By The Revenue Against The Common Order Dated 29.12.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As The ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). Since The Facts & Issued Involved In Both The Appeals Are Identical & Both The Appeals Are Arising Out Of The Same Order Of The Ld.

Section 143(3)Section 250Section 68

facts in brief are that the assessee is an individual and filed his return of income on 13.02.2018 which was selected for limited scrutiny on the ground of huge cash withdrawals. Accordingly, the Assessing Officer issued notices including questionnaire which were duly served upon the assessee. The assessee is engaged

Sitaram Pareek, Kolkata vs. ITO, Ward-36(1), Kolkata

In the result, the appeal of the assessee is allowed, whereas, the appeal of the revenue is dismissed

ITA 378/KOL/2024[2017-18]Status: DisposedITAT Kolkata11 Mar 2025AY 2017-18

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyi.T.A. No.378/Kol/2024 Assessment Year: 2017-18 Sitaram Pareek………………....…………...………......................……….……Appellant Ca Anup Kumar Sanghai Sanghai & Co, Ca 21, Hemanta Basu Sarani, 2Nd Floor, Room No.204, Kolkata -1. [Pan:Alqpp5688N] Vs. Ito, Ward-36(1), Kolkata..............…..….…..….........……........……...…..…..Respondent I.T.A. No.653/Kol/2024 Assessment Year: 2017-18 Ito, Ward-36(1), Kolkata ………………....………......................……….……Appellant Vs. Sitaram Pareek..............…..….…..…..........................……........……...…..…..Respondent Ca Anup Kumar Sanghai Sanghai & Co, Ca 21, Hemanta Basu Sarani, 2Nd Floor, Room No.204, Kolkata -1. [Pan:Alqpp5688N] Appearances By: Shri Anup Sanghai, Fca, Appeared On Behalf Of The Appellant. Shri Abhijit Adhikari, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : March 10, 2025 Date Of Pronouncing The Order : March 11, 2025 Order Per Rajesh Kumar: The Captioned Are Cross-Appeals, One By The Assessee & The Other By The Revenue Against The Common Order Dated 29.12.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As The ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). Since The Facts & Issued Involved In Both The Appeals Are Identical & Both The Appeals Are Arising Out Of The Same Order Of The Ld.

Section 143(3)Section 250Section 68

facts in brief are that the assessee is an individual and filed his return of income on 13.02.2018 which was selected for limited scrutiny on the ground of huge cash withdrawals. Accordingly, the Assessing Officer issued notices including questionnaire which were duly served upon the assessee. The assessee is engaged

Shree Siddheshwar Co-Op Credit Society Limited, Belagavi vs. Assessing Officer, National E-Assessment Centre, Delhi

In the result, the appeal filed by the appeal is allowed

ITA 302/PAN/2024[2017-18]Status: DisposedITAT Panaji07 Mar 2025AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos. 302/Pan/2024 (A.Y. 2017-18 ) Shree Siddheshwar Co-Op Vs Ito-Ward-6, Civil Hospital Road, Credit Society Limited, . Belagavi-590001. P B Road, Kakati, Karnataka. Belgaum-591113, Karnataka. . Pan .No. Aaifs6553Q (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By Shri.Santosh Kumar Dlatthe.Ar Revenue By Shri.Manikandan.S.Sr.Dr सुनवाई क" तार"ख/Date Of Hearing 06.03.2025 घोषणा क" तार"ख/Date Of Pronouncement 07.03.2025 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of Nfac/Cit(A) Passed U/Sec 143(3) & U/Sec 250 Of The Act. 2. At The Time Of Hearing, The Ld.Ar Of The Assessee Submitted That There Is A Delay In Filing The Appeal Before The Hon’Ble Tribunal & The Assesse Has Filed The Affidavit For Condonation Of Delay. Whereas, The Facts Mentioned In The Affidavit Are Reasonable & The Ld. Dr Has No Specific Objections. Accordingly, We Condone The Delay & 2 Ita. No..302/Pan/2024 Shri Siddeswar Co-Op Society Limited.. Admit The Appeal. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Denial Of Claim Of Deduction Under Section 80P(2)(D) Of The Act.

Section 143(1)Section 80PSection 80P(2)(d)

disclosing a total income of Rs.Nil after claiming deduction u/sec 80P of the Act. Subsequently the case was selected for Limited scrutiny under CASS and notice u/sec 143(2) & u/sec 142(1) of the Act are issued. In compliance, the assesse has filed the details and submissions in support

Radha Madhav Eco-Industrial Park, Valsad vs. Asstt. Commissioner of Income Tax, Central Circle-1, Vapi

In the result, appeal of the assessee is partly allowed and appeal of revenue is dismissed

ITA 632/SRT/2024[2018-19]Status: DisposedITAT Surat05 Mar 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.762/Srt/2023 Assessment Year: (2021-22) (Hybrid Hearing) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.41/Srt/2024 Assessment Year: (2021-22) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita Nos.625/Srt/2024 Assessment Year: (2018-19) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.632/Srt/2024 Assessment Year: (2018-19) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent)

Section 139Section 250

case of Sudman Consultants LLP (supra), the assessee filed return for AY.2018-19 on 16.08.2019. The case was selected for Radha Madhav Eco-Industrial Park limited scrutiny under e-assessment scheme and order u/s 143(3) was passed on 23.03.2021. Subsequently, notice u/s 148A(b) was issued on 21.03.2022, requiring

Assistant Commissioner of Income Tax, Central Circle, Vapi vs. Radha Madhav Eco Industrial Park, Vapi

ITA 626/SRT/2024[2019-20]Status: DisposedITAT Surat05 Mar 2025AY 2019-20

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.762/Srt/2023 Assessment Year: (2021-22) (Hybrid Hearing) Vs. The Acit, Radha Madhav Eco-Industrial Park, Central Circle - 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District - Valsad – 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.41/Srt/2024 Assessment Year: (2021-22) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District - Valsad - 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita Nos.625/Srt/2024 Assessment Year: (2018-19) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp - Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District - Valsad – 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.632/Srt/2024 Assessment Year: (2018-19) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp - Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District - Valsad - 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent)

Section 139Section 250

IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI BIJAYANANDA PRUSETH, ACCOUNTANT

Radha Madhav Eco-Industrial Park, Vapi vs. ACIT, Centarl Circle-1, Vapi

In the result, appeal of the assessee is partly allowed and appeal of revenue is dismissed

ITA 41/SRT/2024[2021-22]Status: DisposedITAT Surat05 Mar 2025AY 2021-22

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.762/Srt/2023 Assessment Year: (2021-22) (Hybrid Hearing) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.41/Srt/2024 Assessment Year: (2021-22) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita Nos.625/Srt/2024 Assessment Year: (2018-19) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.632/Srt/2024 Assessment Year: (2018-19) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent)

Section 139Section 250

case of Sudman Consultants LLP (supra), the assessee filed return for AY.2018-19 on 16.08.2019. The case was selected for Radha Madhav Eco-Industrial Park limited scrutiny under e-assessment scheme and order u/s 143(3) was passed on 23.03.2021. Subsequently, notice u/s 148A(b) was issued on 21.03.2022, requiring