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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

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

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

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

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

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

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

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

Usha Patodia, Kolkata vs. ITO, Ward - 30(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1969/KOL/2024[2017-18]Status: DisposedITAT Kolkata08 Jan 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Ito, Ward 30(1) Usha Patodia Aaykar Bhavan Dakshin, 2, 3, Tollygunge Circular Road, Gariahat Road (South) Vs. Kolkata-700053, West Bengal Kolkata-700031, West Bengal (Appellant) (Respondent) Pan No. Aevpp4105L Assessee By : Shri S.M. Surana, Ar Revenue By : Shri Sallong Yaden, Dr Date Of Hearing: 19.12.2024 Date Of Pronouncement : 08.12.2025

For Appellant: Shri S.M. Surana, ARFor Respondent: Shri Sallong Yaden, DR

Section 115BSection 69A

assessee filed his return of income on 20.04.2017, declaring total income at Rs.12,80,028. The case of the assessee was selected for limited scrutiny for examination of cash deposited during demonetization period. The statutory and other notices were issued along with questionnaire which were duly served upon the assessee

Sujit Biswas, Nadia vs. I.T.O., Ward - 41(2), Nadia

In the result, the appeal of the assessee is allowed

ITA 1515/KOL/2024[2016-2017]Status: DisposedITAT Kolkata08 Jan 2025AY 2016-2017

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Ito, Ward 41(2) Income Tax Officer, Sujit Biswas Vill-Nakadipara, P.O. Pritinagar, Anantahari Mitra Road, Vs. Nadia, West Bengal-741247 Nodiepara, Krishnagar, Nadia, West Bengal-741101 (Appellant) (Respondent) Pan No. Bfpbb8287K Assessee By : Shri Dilip Chatterjee, Ar Revenue By : Shri P.N. Barnwal, Dr Date Of Hearing: 12.12.2024 Date Of Pronouncement : 08.01.2025

For Appellant: Shri Dilip Chatterjee, ARFor Respondent: Shri P.N. Barnwal, DR

Section 143(3)Section 271ASection 271BSection 44ASection 68

sale of vegetables and also acting as a commission agent on behalf of fruit suppliers/ growers. The case of the assessee was selected for limited scrutiny for verification of cash deposits into the bank account. Accordingly, the statutory notices were duly issued and served upon the assessee Sujit Biswas

Ajay Agarwal, Jaipur vs. CIT (It), Delhi-1, CIT(It) Delhi

In the result, the appeal of the assessee is allowed

ITA 637/JPR/2024[2018-19]Status: DisposedITAT Jaipur08 Jan 2025AY 2018-19

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: MS Suhani Meharwal, CAFor Respondent: Sh. Arvind Kumar, CIT-DR

Section 129Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 195Section 263

compute income of the assessee considering the co-ownership of capital assets sold by assessee when (a) the case was taken in limited scrutiny, (b) the aseeseement was neither erroneous nor prejudicial to the interest of revenue and therefore the direction is without jurisdiction and liable to be quashed ... issued by CBDT the AO was not allowed to expand the scope of scrutiny without obtaining prior approval from appropriate authority in case of limited scrutiny cases. Here, the Ld CIT in the garb of revision tried to enhance the scope of scrutiny, which is not permissible

Deputy Commissioner of Income Tax, Circle 1(1), Jabalpur vs. Shri Indrabhan Singh Rathore, Narsinghpur

In the result, appeal filed by the Revenue is dismissed

ITA 234/JAB/2018[2015-16]Status: HeardITAT Jabalpur08 Jan 2025AY 2015-16

Bench: Sh. Kul Bharat & Sh. Nikhil Choudhary

For Appellant: Shri. Aok Bhura, DRFor Respondent: Shri Sapan Usrethe, Adv

Section 143(3)Section 250Section 68

respect of the sub/petty contractors, from whom these deposits had been received. In reply the assessee submitted that the case had been selected for limited scrutiny on four accounts, including for unsecured loans, but the learned Assessing Officer was asking questions with regard to secured loans which was outside ... deposits made to the Government Department, they could not be called unsecured loans and therefore, could not be brought within the ambit of limited scrutiny as laid down by the CASS. The ld. AR further invited our attention to page 17 of his paper book, which contained the details

Mr. Alli Usman Aga, Bicholim vs. Income Tax Officer, International Taxation Ward, Panaji

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

ITA 77/PAN/2024[2017-18]Status: DisposedITAT Panaji07 Jan 2025AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos. 77/Pan/2024 (A.Y. 2017-18) Alli Usman Aga, Vs Ito, H.No.093, Gokul Wadi International Tax . Sanquelim,Noth Goa, Ward,Pundalik Niwas, Bicholim-403505, Cortim, Goa. Panaji-403001, Goa. . Pan .No. Agnpa7597F (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 69A

ITBA data, found that the assesse has made cash deposits in the bank accounts during the demonetization period and the case was selected for limited scrutiny and further the notice u/sec143(2) and u/sec 142(1) of the Act along with questionnaire are issued. And there was compliance

Shri Saikrupa Nagari Sahakari Patsanstha Maryadit Kolhapur, Kolhapur vs. Circle 1, Kolhapur

In the result, the appeal of the assessee is allowed

ITA 2378/PUN/2024[A.Y. 2018-19]Status: DisposedITAT Pune07 Jan 2025

Bench: Dr.Manish Borad

For Appellant: NoneFor Respondent: Shri Vinod Pawar

Section 143(2)Section 143(3)Section 250Section 56Section 80PSection 80P(2)(d)

furnished on 22.10.2018 declaring Nil income after claiming deduction under Chapter VIA at Rs.26,32,236/-. After the case selected for Limited Scrutiny followed by validly serving of statutory notices u/s.143(2)/142(1), the assessee filed the requisite details. Based on the information furnished by the assessee, the Assessing

Ankalan Web Solutions Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-1(1)(1), Bangalore

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

ITA 1404/BANG/2024[2018-19]Status: DisposedITAT Bangalore07 Jan 2025AY 2018-19

Bench: Shri. Waseem Ahmed & Shri. Keshav Dubeyassessment Year : 2018-19

For Appellant: Shri. Rajendra Sharma, CAFor Respondent: Shri. V. Parithivel, JCIT(DR)(ITAT), Bangalore

Section 142(1)Section 143(3)Section 250Section 69B

before the time of hearing.” 2. The brief facts of the case are that the case of the assessee company was selected for limited scrutiny assessment under the e-assessment scheme, 2019, on the only issue of “Investment in intangible assets”. Thereafter, notices under section

Inner Wheel Club of Delhi Mid Town, New Delhi vs. ACIT-CPC-Banglore, Banglore

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

ITA 1103/DEL/2024[2021-22]Status: DisposedITAT Delhi07 Jan 2025AY 2021-22

Bench: Shri Prakash Chand Yadav & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Vikram Singh Sharma, Sr DR

Section 143(1)Section 143(2)Section 144Section 271ASection 68

Income was subsequently processed u/s 143(1) of the Income-tax Act, 1961 [the Act, for short]. Later the case was selected for limited scrutiny under CASS due to the reason “large balance in foreign bank account". Thereafter, notices u/s 143(2) of the Act were issued and served upon

The Kankrej Taluka Shihori Co. Op. Purchase & Sale Union Ltd., Banaskantha vs. The Dy.CIT, Gandhinagar Circle, Gandhinagar

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

ITA 803/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad06 Jan 2025AY 2018-19

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Makarand V. Mahadeokar (Accountant Member)

For Appellant: Shri Dhinal Shah, A.RFor Respondent: Shri Nitin Vishnu Kulkarni, Sr. D.R

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

income of Rs. nil after claiming deduction u/s. 80P of the Act of Rs. 28,35,712/-. The assessee’s case was selected for limited scrutiny assessment in respect of deduction from total income under chapter VI-A. Notice u/s. 143(2) of the Act was issued ... with these proceedings. Thus, this contention of the assessee will not be applicable in the present case as the assessment has been selected for limited scrutiny on the issue of deduction under chapter VIA and the assessment is concluded u/s. 143(3) of the Act. Thus, this contention is rejected

Dnyaneshwar More Bigarshet Gramin Pat Puravatha Sahakari Sanstha Ltd, Solapur vs. ITO Ward 2, Pandharpur

In the result, appeal of the assessee is allowed

ITA 2397/PUN/2024[2017-18]Status: DisposedITAT Pune06 Jan 2025AY 2017-18

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.2397/Pun/2024 Assessment Year : 2017-18

For Appellant: Shri S.N. PuranikFor Respondent: Shri Sourabh Nayak

Section 143(2)Section 143(3)Section 250Section 56Section 80PSection 80P(2)(d)

income after claiming deduction under Chapter VIA at Rs.13,48,854/- while claiming business loss at Rs.3,56,511/-. After the case selected for Limited Scrutiny following by statutory notices u/s.143(2)/142(1), the assessee filed the requisite details. Based on the information furnished by the assessee, the Assessing

The Salsette Catholic Co-Operative Housing Society Limited, Mumbai vs. Assistant Commissioner of Income Tax, Circle 23(3), Mumbai

In the result, the appeals filed by the assessee are allowed

ITA 5894/MUM/2024[2016-17]Status: DisposedITAT Mumbai06 Jan 2025AY 2016-17

Bench: Shri Saktijit Dey & Smt. Renu Jauhri

For Appellant: Shri Shashank MehtaFor Respondent: Shri Ram Krishn Kedia

Section 250Section 80P(2)(d)

deposits with Saraswat Co-operative Bank and Maharashtra State Co-operative Bank amounting to Rs. 3,04,21,874/-. The case was selected for limited scrutiny and assessment was completed at an income of Rs. 4,03,39,880/- after making addition on account of interest

The Salsette Catholic Co Operative Housing Society Limited, Mumbai vs. ACIT, Circle 23(3), Mumbai

In the result, the appeals filed by the assessee are allowed

ITA 5893/MUM/2024[2017-18]Status: DisposedITAT Mumbai06 Jan 2025AY 2017-18

Bench: Shri Saktijit Dey & Smt. Renu Jauhri

For Appellant: Shri Shashank MehtaFor Respondent: Shri Ram Krishn Kedia

Section 250Section 80P(2)(d)

Muniyappa Govindraj, Kgf vs. Income Tax Officer, Ward-1, Kolar

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

ITA 2280/BANG/2024[2018-19]Status: DisposedITAT Bangalore06 Jan 2025AY 2018-19

Bench: Shri Prashant Maharishi & Shri Prakash Chand Yadavassessment Year: 2018-19

For Appellant: Mr. Syed Asfaq Ahmed Nadeem Lasani, A.RFor Respondent: Ms. Nandini Das, D.R

income tax return electronically on 5.10.2018 declaring an income of Rs.9,75,300/-. Thereafter, the case of the assessee was picked up for limited scrutiny. During the course of assessment proceedings, various documents were called for by the AO with respect to the source of cash deposited in the bank

Chandrashekar Hemanth, Bengaluru vs. Income Tax Officer Ward 7(2)(4) Bangalore, Bengaluru

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

ITA 1677/BANG/2024[2017-18]Status: DisposedITAT Bangalore06 Jan 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Siddesh Nagaraj Gaddi, CAFor Respondent: Shri Sridhar E, CIT-DR

Section 139(1)Section 143(2)Section 250Section 69ASection 80

giving due consideration of the facts and records lying before the officer. 2. The impugned order of the Ld.AO, being beyond the scope of limited scrutiny, is bad in law; Page 2 of 14 3. The learned CIT(A) and AO had erred in passing an order without duly considering

Yad Dharam Satya Trust, Delhi vs. CIT Exemptions, Delhi

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

ITA 2037/DEL/2024[2024-25]Status: DisposedITAT Delhi06 Jan 2025AY 2024-25

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Salil Aggarwal, Sr. AdvFor Respondent: Shri Sanjeev Kaushal, CIT-DR

Section 143(2)Section 143(3)Section 147Section 148Section 149(1)(a)Section 150Section 68

return of income for the A.Y. under consideration on 27.09.2015 declaring total income of Rs. 77,28,950/-. The case was selected for limited scrutiny through CASS and accordingly, notice u/s 143(2) of the Income-tax Act, 1961 [the Act, for short] was issued on 12.04.2016 which was duly

Subhash Chander Oberoi, Mumbai vs. Asst Commissioner of Income Tax - 26(3), Mumbai

In the result, the appeal by the assessee is allowed

ITA 1667/MUM/2024[2014-15]Status: DisposedITAT Mumbai06 Jan 2025AY 2014-15

Bench: Shri Amarjit Singhshri Sandeep Singh Karhailsubhash Chander Oberoi, Saidham Building, Dr. Jawkar Lane, Sion Chunabhatti Road, Mumbai - 400022 ……………. Appellant Maharashtra Pan: Aadpo9185B V/S Acit, 26(3), Kautilya Bhavan, Bandra Kurla Complex, ……………. Respondent Mumbai - 400051 Maharashtra

For Appellant: Shri Dharan Gandhi, AdvFor Respondent: Dr. Kishor Dhule – CIT-DR

Section 142(1)Section 143(2)Section 2(22)(e)Section 250Section 271(1)(c)

tune of INR 6,34,58,869. In order to verify the issue, the case was converted into complete scrutiny as against limited scrutiny. During the assessment proceedings, the assessee was asked to show cause why the advance received from the said company should not be treated as deemed dividend

Income Tax Officer, Kolkata vs. Uniglobal Papers Private Limited, Kolkata

In the result, the appeal of the assessee is allowed

ITA 2182/KOL/2024[2013-14]Status: DisposedITAT Kolkata06 Jan 2025AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Singh Construction Dcit, Central Circle-2 Corporation Aaykar Bhawan, Aayakar Bithi Nachan Rad, Bhiringee, City Centre, City Centre, Durgapur, Burdwan, Vs. Durgapur, West Bengal Kolkata 713213 Pin-713216 West Bengal (Appellant) (Respondent) Pan No. Abjfs8820N Assessee By : S/Shri Manoj Kataruka & Siddharth Ray, Ars Revenue By : Shri S.B. Chakraborthy, Dr Date Of Hearing: 04.12.2025 Date Of Pronouncement: 18.12.2025

For Appellant: S/shri Manoj Kataruka &For Respondent: Shri S.B. Chakraborthy, DR

Section 143(2)Section 194CSection 69C

Singh Construction Corporation; A.Y. 2018-19 2.1. The facts in brief are that the case of the assessee was selected for limited scrutiny for verification of genuineness of expenses (large payment made u/s 194C) to the persons who had not filed the return of income. Accordingly, notice

The State Transport Employees Co Operative Credit Thrift Society, Mehsana vs. DCIT, Circle, Gandhinagar

In the result, the appeal of the assessee is partly allowed

ITA 1937/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad03 Jan 2025AY 2018-19

Bench: Ms. Suchitra Kamble

For Appellant: Shri Sunil Talati, A.RFor Respondent: Shri C Dharani Nath, Sr. D.R

Section 142(1)Section 40A(7)Section 56Section 57Section 80PSection 80P(2)(d)

Cooperative Societies Act, Gujarat and engaged in the business of banking / providing credit facilities to its members. The assessee’s case was selected for limited scrutiny in respect of the issues that of investment / advances / loans, disallowance under Section 40A(7) (Gratuity provision) and deduction from total income under Chapter

Patel Minerals Pvt. Ltd., Udaipur vs. ACIT, Circle-1, Udaipur

In the result, the appeal of the assessee is allowed

ITA 22/JODH/2024[2015-16]Status: DisposedITAT Jodhpur02 Jan 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI, J (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

Section 142Section 143(2)Section 143(3)Section 56Section 56(2)(viib)

Income on 03.09.2015 declaring therein total income as NIL by claiming loss of Rs (- )758076/-. The case of the assessee was selected for limited scrutiny and accordingly notice u/s 143(2) dated 13.04.2016 was issued and duly served upon the assessee, fixing the case for hearing on 29.04.2016. A detailed ... Appellant company filed its return of income declaring a loss of Rs 7,58,076/- on 03.09.2015. 3. Aforesaid return was picked up for limited scrutiny to verify share premium, however same was converted into full scrutiny later on. 4. Learned AO completed assessment u/s 143(3) on 08.12.2017 with

M/S. Subhrashi Enclave Pvt. Ltd., Kolkata vs. ITO, 10 (2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1963/KOL/2024[2015-16]Status: DisposedITAT Kolkata02 Jan 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.1963/Kol/2024 Assessment Year: 2015-16 M/S Subhrashi Enclave Pvt. Ltd...…..…………………....Appellant 14-C, M.D. Road, 4Th Floor, Kolkata – 700007. [Pan: Aascs6378Q] Vs. Ito, Ward-10(2), Kolkata…. ….…….…............................…..…..... Respondent Appearances By: Shri Manoj Kataruka, Ar, Appeared On Behalf Of The Appellant. Shri S.B. Chakraborthy, Addl. Cit & Somnath Das & Somnath Das Biswas, Sr. Drs, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2024 Date Of Pronouncing The Order : January 02, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 01.09.2023 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. The Appeal Is Time-Barred By 324 Days. An Application For Condonation Of Delay Has Been Filed, Which Is Also Supported With The Affidavit Of Shri Subhash Sharma, The Director Of The Assessee Company, Wherein, It Has Been Pleaded That The Impugned Order Of The Cit(A) Was Passed On 01.09.2023 But The Order Was Communicated To The Assessee On 03.09.2024. Immediately, The Assessee Engaged An Authorized Representative & Filed The Appeal. The Ld. Ar Further Stated That The Notice & Also The Impugned Order Were Not Duly Served Upon The Assessee Due To Mismatch Of Email Address Which Was Provided In Form 35. Therefore, The Assessee Was Not Aware Of The Passing Of The

Section 143(2)Section 250

return of income for the assessment year 2015-16 by declaring total income of Rs.2,530/-. The case of the assessee was selected for limited scrutiny based on specific issues including low income in comparison to very high loans/advances/investments in the balance sheet, mismatch in profit before ... before this Tribunal raising multiple grounds. However, the main contention of the ld. AR is that the Assessing Officer went beyond the scope of limited scrutiny without obtaining prior approval for complete scrutiny. Moreover, the assessee furnished all necessary details/supporting documents such as copies of ITR, audited accounts, salary payment