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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Vijay Fomra, Kolkata vs. ITO, Ward 40(1), Kolkata

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

ITA 2729/KOL/2025[2016-2017]Status: DisposedITAT Kolkata02 Feb 2026AY 2016-2017

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.2729/Kol/2025 Assessment Year: 2016-17 Vijay Fomra…………………..………………....…………………....Appellant 57, Fomra House Burtolla Street, Burrabazar, Kol-7.. [Pan: Aadpf7609P] Vs. Ito, Ward-40(1), Kolkata..…….……....…..………………….…..... Respondent Appearances By: Shri Sonal Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri Mrinmoy Basak, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 02, 2026 Date Of Pronouncing The Order : February 02, 2026 आदेश / Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Addl/Jcit(A)-2, Pune (Hereinafter Referred To As “Ld. Cit(A)”) Dated 15.09.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Filed Return Of Income Declaring A Total Income Of ₹4,98,860. The Case Of The Assessee Was Selected For Limited Scrutiny Through Cass. The Assessing Officer Completed Assessment U/S 143(3) By Making Certain Additions. 3. Aggrieved By The Assessment Order, The Assessee Preferred An Appeal Before The Cit(A). However, There Was A Delay Of 74 Days In Filing The Appeal. The Learned Cit(A) Dismissed The Appeal Solely On The

Section 143(3)Section 250

that the assessee filed return of income declaring a total income of ₹4,98,860. The case of the assessee was selected for limited scrutiny through CASS. The Assessing Officer completed assessment u/s 143(3) by making certain additions. 3. Aggrieved by the assessment order, the assessee preferred an appeal