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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

ACIT, Central Circle, Vapi vs. Radha Madhav Eco Industrial Park, Vapi

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

ITA 762/SRT/2023[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

Devi Chitra Eknath Kuba, Madurai vs. ITO, Ncw-2(1), Madurai

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

ITA 3027/CHNY/2024[2018-19]Status: DisposedITAT Chennai05 Mar 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.3027/Chny/2024 िनधा"रण वष"/Assessment Year: 2018-19 Devi Chitra Eknath Kuba, Vs. The Income Tax Officer, 1B, Patchariskara Thoppu, Cross Non Corporate Ward 2(1), Street, Kamarajar Street, Madurai. Madurai 625 009. [Pan:Alspk7617A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri R. Thulasi Ram, Advocate, : Shri Sathish Kumar, Advocate & Shri Kumar Subramanian, Advocate ""थ" की ओर से/Respondent By : Shri A. Sasikumar, Cit सुनवाई की तारीख/ Date Of Hearing : 26.02.2025 घोषणा की तारीख /Date Of Pronouncement : 05.03.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 13.02.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2018-19. 2. We Find That This Appeal Is Filed With A Delay Of 211 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, We

For Respondent: Shri A. Sasikumar, CiT
Section 133(6)Section 142(1)Section 69C

case are that the assessee filed the return of income declaring total income of ₹.9,12,580/-. The said case was selected for limited scrutiny for verification of genuineness of expenses. Against the statutory notices, the assessee filed relevant requisite documents before the Assessing Officer. Against the notice under section

The New India Multi Purpose Co-Op Society Limited, Mapusa vs. Income Tax Officer, Ward - 1(4), Panaji

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

ITA 244/PAN/2024[2017-18]Status: DisposedITAT Panaji04 Mar 2025AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos. 244/Pan/2024 (A.Y. 2016-17 ) The New India Multi Vs Ito-Ward-1(4), Aayakar Bhavan, Purpose Co-Op Society Ltd, . Plot.No 5, Edc C/2,Ug Floor, Saidanha Complex,Patto Plaza, Business Towers,Near Panaji.-403001, Court Circle, Bardez Goa. Mapusa-403607 . Goa. Pan .No. Aadat8151H (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By Shri. Amogh Arlekar.Ar Revenue By Shri.Manikandan.S.Sr.Dr सुनवाई क" तार"ख/Date Of Hearing 03.03.2025 घोषणा क" तार"ख/Date Of Pronouncement 04.03.2025 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of Addl/ Jcit(A) Kolkata Passed U/Sec 143(3) & U/Sec 250 Of The Act. 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. 2. The Brief Facts Of The Case Are That, The Assessee Is A Cooperative Society Registered Under The Maharashtra Co-

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

Nashik District Primary Teachers Co-Op Credit Society Ltd, Nashik vs. ITO Ward 1(1), Nashik

In the result, the appeal of the assessee in ITA No

ITA 2071/PUN/2024[2021-22]Status: DisposedITAT Pune28 Feb 2025AY 2021-22

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.2070 & 2071/Pun/2024 निर्धारण वर्ष / Assessment Years : 2018-19 & 2021-22 Nashik District Primary Teachers Co-Op Credit Society Ltd., Saraswati Complex, Malviya Chowk, Panchavatikaranja, Nashik-422002 Vs. Ito, Ward – 1(1), Nashik Pan: Aaaan2859D अपीलार्थी /Appellant प्रत्यर्थी / Respondent Assessee By : Shrisanket Joshi Department By : Shriramnath P. Murkunde Date Of Hearing : 31-12-2024 Date Of Pronouncement : 28-02-2025 आदेश / Order Per Astha Chandra, Jm : These Two Appeals Filed By The Assessee Is Directed Against The Two Separate Orders Both Dated 22.08.2024 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)”] Pertaining To Assessment Year (“Ays”) 2018- 19 & 2021-22. Since The Issues Involved Are Identical The Same Were Heard Together & Are Disposed Of By This Common Order.

For Appellant: ShriSanket JoshiFor Respondent: ShriRamnath P. Murkunde
Section 143(1)Section 144Section 80PSection 80P(2)(a)

case was processed u/s 143(1) of the Income Tax Act, 1961. Subsequently, the case was selected under CASS for limited scrutiny to verify 'Deduction claimed under Chapter VI. During the assessment proceeding various notices were issued and served to the assessee. But the assessee failed to comply with these

M/S Funidea Vinimay Pvt. Ltd., Kolkata vs. I.T.O., Ward-5(1), Kolkata

The appeal of the assessee is allowed

ITA 2583/KOL/2024[2017-18]Status: DisposedITAT Kolkata28 Feb 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.2583/Kol/2024 Assessment Year: 2017-18 M/S Funidea Vinimay Pvt. Ltd.…………………………………..….……….Appellant 2, Lal Bazar Street, 1St Floor, Kolkata -1. [Pan: Aabcf9340C] Vs. Ito, Ward-5(1), Kolkata...……..............................……........……...…..…..Respondent Appearances By: Shri Manoj Kataruka, Advocate, Appeared On Behalf Of The Assessee. Shri Sailen Samadder, Addl. Cit- Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : February 27, 2025 Date Of Pronouncing The Order : February 28, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 11.12.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Assessment Year 2017-18 By Declaring Total Income Of Rs.33,511/-. The Case Of The Assessee Was Selected For Scrutiny Assessment Under Limited Scrutiny Criteria For The Reason Of Selection Of Low Income Compared To High Loans/Advances/Investment In Shares Appearing In Balance Sheet & Expenses Debited To P&L A/C For Earning Exempt Income As Per Schedule Bp Of Itr Is Significantly Lower As Compared To Investments Made To Earn Exempt Income. Subsequently, Notice U/S 143(2) Of The Act Was Issued To The Assessee & Also Notice

Section 142(1)Section 143(2)Section 250

assessment year 2017-18 by declaring total income of Rs.33,511/-. The case of the assessee was selected for scrutiny assessment under limited scrutiny criteria for the reason of selection of low income compared to high loans/advances/investment in shares appearing in balance sheet and expenses debited ... permissible under the law. He further I.T.A. No.2583/Kol/2024 Assessment Year: 2017-18 M/s Funidea Vinimay Pvt. Ltd stated that the assessment was conducted under limited scrutiny without converting into complete scrutiny with due approval from the competent authority rendering the order erroneous. Besides that while passing the order

Sultanpur Juth Seva Sahakari Mandali Ltd., Sultanpur, Tal. Gondal, Dist. Rajkot vs. The DCIT, Circle-1 (1), Rajkot

In the result, appeal filed by the assessee is allowed

ITA 697/RJT/2024[2018-19]Status: DisposedITAT Rajkot27 Feb 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.492 & 493 & 697/Rjt/2024 ("नधा"रण वष"/Assessment Year: (2018-19 & 2020-21) Sultanpur Juth Seva Sahkari Assessment Unit, Nfac Mandali Ltd. (Present Juris. Acit-Dcit Vs. Cir-1(1) Sultanpur, At Sultanpur Tal: Gondal, Dist. It Office, New Aayakar Bhavan, Vatiaka, Rajkot – 364470 Rajkot - 360001 "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Aaabs0194F (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Sulabh Pad Shah, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 142(1)Section 143(3)Section 270ASection 80P(2)(a)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

Sultanpur Juth Seva Sahkari Mandli Ltd, Rajkot vs. Assessment Unit, NFAC (Present Juris. ACIT-DCIT Cir 1(1), Rajkot

In the result, appeal filed by the assessee is allowed

ITA 493/RJT/2024[2020-21]Status: DisposedITAT Rajkot27 Feb 2025AY 2020-21

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.492 & 493 & 697/Rjt/2024 ("नधा"रण वष"/Assessment Year: (2018-19 & 2020-21) Sultanpur Juth Seva Sahkari Assessment Unit, Nfac Mandali Ltd. (Present Juris. Acit-Dcit Vs. Cir-1(1) Sultanpur, At Sultanpur Tal: Gondal, Dist. It Office, New Aayakar Bhavan, Vatiaka, Rajkot – 364470 Rajkot - 360001 "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Aaabs0194F (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Sulabh Pad Shah, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 142(1)Section 143(3)Section 270ASection 80P(2)(a)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

Sultanpur Juth Seva Sahkari Mandli Ltd, Rajkot vs. Assessment Unit, NFAC (Present Juris. ACIT-Dict Cir 1(1) Rajkot), Rajkot

In the result, appeal filed by the assessee is allowed

ITA 492/RJT/2024[2018-19]Status: DisposedITAT Rajkot27 Feb 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.492 & 493 & 697/Rjt/2024 ("नधा"रण वष"/Assessment Year: (2018-19 & 2020-21) Sultanpur Juth Seva Sahkari Assessment Unit, Nfac Mandali Ltd. (Present Juris. Acit-Dcit Vs. Cir-1(1) Sultanpur, At Sultanpur Tal: Gondal, Dist. It Office, New Aayakar Bhavan, Vatiaka, Rajkot – 364470 Rajkot - 360001 "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Aaabs0194F (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Sulabh Pad Shah, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 142(1)Section 143(3)Section 270ASection 80P(2)(a)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