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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Karnataka Telecom Department Employees Co-Operative Society Limited, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle 1(4), Blr, Bengaluru

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

ITA 1083/BANG/2025[2022-23]Status: DisposedITAT Bangalore30 Jan 2026AY 2022-23

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri PR Suresh, CAFor Respondent: Shri N Balusamy, JCIT-DR

Section 142(1)Section 250Section 56Section 80PSection 80P(2)Section 80P(2)(a)

after claiming deduction u/s 80P of the Act at Rs. 46,85,779/- only. The case of the assessee was selected for limited scrutiny and in order to verify the claims of the assessee notices were issued time to time u/s 142(1) of the Act. 4. Finally

Karnataka Telecom Department Employees Co-Operative Society Limited, Bengaluru vs. Deputy Commissioner of Income of Tax, Central Circle 1(4), Blr, Bengaluru

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

ITA 1082/BANG/2025[2020-21]Status: DisposedITAT Bangalore30 Jan 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri PR Suresh, CAFor Respondent: Shri N Balusamy, JCIT-DR

Section 142(1)Section 250Section 56Section 80PSection 80P(2)Section 80P(2)(a)

Karnataka Telecom Department Employees Co-Operative Society Limited, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle 1(4), Blr, Bengaluru

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

ITA 1081/BANG/2025[2018-19]Status: DisposedITAT Bangalore30 Jan 2026AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri PR Suresh, CAFor Respondent: Shri N Balusamy, JCIT-DR

Section 142(1)Section 250Section 56Section 80PSection 80P(2)Section 80P(2)(a)

Gnana Kathir Singarayar, Mumbai vs. ITO, Mumbai

In the result, the appeal is allowed for statistical purposes

ITA 5502/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Jan 2026AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankargnana Kathir Singarayar, V/S. Income Tax Officer, Piramal Room No.1, Row N Block बनाम Chambers, Lalbaug, Mumbai No. 12, Transit Camp, - 400012, Maharashtra Dharavi, Mumbai - 400 017, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Apyps5634M Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: NoneFor Respondent: Shri Swapnil Choudhary (Sr. AR)

Section 115BSection 143(2)Section 143(3)Section 144

orders are that the assessee filed the Return of Income, declaring a total income of Rs. 9,72,120/-. The case was selected for limited scrutiny under CASS. During the assessment proceedings, it was observed that he had deposited a substantial amount of cash, totalling

Vijay Raaz, Godbundar Road, Dist. Thane vs. Ward 16(1)(5), Mumbai

In the result, the appeal filed by the assessee is hereby dismissed

ITA 3416/MUM/2025[2020-2021]Status: DisposedITAT Mumbai30 Jan 2026AY 2020-2021

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm Vijay Raaz Ward 16(1)(5), Mumbai Cottage No. B-13, Cosmos Hawaiian, Near Blue Roof Club, Ghodbunder Vs. Road, Thane, West 400 601. Pan/Gir No. Adlpr8784L (Appellant) (Respondent) :

For Respondent: Shri Vivek Perampurna (CIT-DR)

Section 143(3)Section 263Section 29ASection 80G

assessee, which can be inferred that the Ld. AO has not conducted any enquiry into the issue which was the subject matter of the limited scrutiny during the assessment proceeding. Further, whether the said party has complied with the conditions specified in section 13A of the Act for claiming exemption

Sh. Ramesh Yadav, Gurgaon vs. ITO Ward-3(5), Gurgaon

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

ITA 2447/DEL/2025[2014-15]Status: DisposedITAT Delhi30 Jan 2026AY 2014-15

Bench: Shri Vimal Kumar & Smt. Renu Jauhriassessment Year 2014-15 Shri Ramesh Yadav, Vs. Income Tax Officer, 236, Sector-6, Manesar Imt, Ward-3(5), Gurgaon, Haryana Gurgaon Pan No. Acbpy6351M Pin: 122016 (Appellant) (Respondent)

For Appellant: Shri Somil Agarwal, Adv. & SakshamFor Respondent: Shri Ajay Kumar Arora, Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 250(6)

assessee. Further, statutory notices u/s 142(1) along with 2 questionnaire was issued on 18.07.2016, fixing the case for 27.07.2016.The case was selected under Limited Scrutiny, which was converted into complete scrutiny with the prior approval of worthy Pr. Commissioner of Income Tax, Gurgaon vide his office letter bearing No.6835

James Christopher, Zuarinagar vs. Income Tax Officer, Ward - 2(4), Panaji

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

ITA 455/PAN/2025[2017-18]Status: DisposedITAT Panaji29 Jan 2026AY 2017-18

Bench: Shri Pavan Kumar Gadalei T A. No.455/Pan/2025 (A.Y. 2017-18) James Christopher, Vs Ito-Ward 2(4), H.No.11, Behind Kiran Niketan Pundalik Niwas, . Prim, Zuarinagar-403726, Rua-De-Qurem, Goa. Cortim,Panaji, Goa-403001, Pan,No.Abmpc9362N (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Sri.Sandesh Padiyar.Ar Revenue By Shri.S.Gurukumar.Sr.Dr सुनवाई की तारीख/Date Of Hearing 22.01.2026 घोषणा की तारीख/Date Of Pronouncement 29.01.2026 Order Per Pavan Kumar Gadale ,Jm: The Assesse Has Filed The Appeal Against The Order Of The Addl/Jcit(A) Thiruvanantpuram 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 U/Sec69A Of The Act Made By The Assessing Officer. 2. The Brief Facts Of The Case Are That, The Assessee Is A Lecturer In Mes College Zuari Nagar, Goa. The Assessee Has Filed The Return Of Income For A.Y.2017-18 On 4.08.2017 Disclosing A Total Income Of Rs.8,54,310/-. Subsequently The Case Was Selected For Limited Scrutiny

Section 69A

filed the return of income for A.Y.2017-18 on 4.08.2017 disclosing a total income of Rs.8,54,310/-. Subsequently the case was selected for Limited Scrutiny 2 ITA. No.455/PAN/2025 James Christopher. and notice u/sec 143(2) and u/sec142(1) of the Act are issued calling for the details. The Assessing Officer

Anand Associates, Silvassa vs. ITO, Ward Silvassa, Silvassa

In the result, the appeal of the assessee is allowed

ITA 973/SRT/2025[2015-16]Status: DisposedITAT Surat29 Jan 2026AY 2015-16

Bench: Ms. Suchitra Kambleassessment Year 2015-16

For Appellant: Shri Chetan Khakhar, A.RFor Respondent: Ms. Jayshree Thakur, Sr. D.R

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

income, at Rs. 2,93,250/-. The same was processed u/s. 143(1) of the Act. The case of the assessee was selected for limited scrutiny. Notice u/s. 143(2) was issued on 27-07-2016 which was duly served upon the assessee. Questionnaire along with notice

Avkar Urben Co-Op Credit Society Limited, Surat vs. ACIT Circle 3(3), Surat

In the result, the appeal of the Assessee is allowed

ITA 971/SRT/2025[2018-19]Status: DisposedITAT Surat29 Jan 2026AY 2018-19

Bench: Ms. Suchitra Kambleassessment Year 2018-19

For Appellant: Shri Aakash Bakashwala, C.AFor Respondent: Ms. Jayshree Thakur, Sr. D.R

Section 80PSection 80P(2)(d)

assessee co-operative society filed the return of income on 14-09-2018 declaring nil income. The case of the assessee was selected for limited scrutiny and statutory notices were issued along with questionnaire. The assessee society submitted its reply. After taking cognizance of the said reply and the submissions

Ajay Singh Bhadoria, Kanpur vs. ITO(1)(1), Kanpur

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

ITA 806/LKW/2025[2015-16]Status: DisposedITAT Lucknow29 Jan 2026AY 2015-16

Bench: Shri Anadee Nath Misshra

Section 143(3)Section 144Section 44A

whereby assessee’s total income was determined at Rs.47,28,041/- as against returned income of Rs.10,63,450/-. The case was selected for limited scrutiny to check whether contract receipts/fee/turnover have been correctly offered for tax and whether refund claim is justified. In the aforesaid assessment order, the Assessing

Vandanaben Rajbhai Parikh, Ahmedabad vs. The Pr.CIT, Ahmedabad-1, Ahmedabad

ITA 1135/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad29 Jan 2026AY 2020-21

Bench: DR. BRR Kumar (Vice President), Shri Siddhartha Nautiyal (Judicial Member)

Section 143(3)Section 144BSection 263Section 80G

section 263 of the Income Tax Act, for an issue which was the sole reason for the selection of scrutiny under CASS for Limited Scrutiny and the same has been verified in-depth by the AO. 2. The PCIT has erred in laws and facts by revising and setting aside ... income for assessment year 2020–21 on 05.12.2020 declaring a total income of Rs. 4,60,65,240/-. The case was selected for limited scrutiny through CASS for the specific reason of “Deduction from Total Income under Chapter VI-A”. During the assessment proceedings, notices under sections

Manackraj Kamaraj, Ambur vs. ITO, Non Corpate Ward 11(2), Chennai

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

ITA 2541/CHNY/2025[2017-18]Status: DisposedITAT Chennai29 Jan 2026AY 2017-18

Bench: Ms. Padmavathy S & Shri Manu Kumar Giriआयकर अपील सं./Ita No. 2541/Chny/2025 "नधा"रण वष"/Assessment Year: 2017-18 V. Manackraj Kamaraj Ito Ncw 11(2) No. 23/10, Ramar Koil Street, Chennai Ambur-635 802. Tamil Nadu [Pan: Alzpk 7476 Q] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 115BSection 143(3)Section 156Section 68

activity. For the relevant assessment year, the assessee filed return of income declaring total income of Rs.4,43,200/-.The case was selected for limited scrutiny under CASS for the specific reason “Credit Card Payments”. Notices u/s.s 143(2) and 142(1) were issued calling for details of credit card ... credits u/s. 68, which applies only where a sum is found credited in the books. He further submitted that the case was selected for limited scrutiny and the AO exceeded jurisdiction by treating the issue as cash credits without approval of the Pr. CIT for conversion into complete scrutiny

DCIT 27(1), Mumbai vs. Ashok Kumar Valchand Jain, Mumbai

In the result, the appeal of the Revenue is dismissed and the Cross Objection of the assessee is allowed

ITA 5887/MUM/2025[2017-18]Status: DisposedITAT Mumbai29 Jan 2026AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 142(1)Section 143(3)Section 36(1)(iii)Section 68

disallowance of Rs.20,94,071/- u/s 36(1)(iii) of the Act is to be deleted as the same was outside the scope of Limited Scrutiny in this case, whereas the case of the assessee was selected for “Complete Scrutiny”? 4. Whether on the facts and circumstances of the case ... reproduced hereunder: 5.6.1 With regards to the additional ground of appeal 1 that additions have been made on issues not covered in limited scrutiny, the appellant submitted that AO travelled beyond his jurisdiction and made the additions/ disallowances of other issues not covered under Limited scrutiny of (a) Disallowance

K. G. Finvest Private Limited, East Delhi vs. Central Circle 29, Delhi, New Delhi

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

ITA 4330/DEL/2025[2015-16]Status: DisposedITAT Delhi29 Jan 2026AY 2015-16

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2015-16] K.G. Finvest Pvt. Ltd. Vs Central Circle-29, F-24 F/Floor, I.Sc Pankaj Delhi Central Market, Mandawali Fazalpur, Nr Natraj Vihar Society, I.P. Extn., New Delhi- 110092. Pan-Aaack4032H Appellant Respondent Appellant By Shri Sudesh Garg, Adv. & Shri Prince Bansal, Ca Respondent By Shri Jitender Singh, Cit Dr Date Of Hearing 26.11.2025 Date Of Pronouncement 29 .01.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 17.06.2025 Passed By Ld. Commissioner Of Income Tax (A)-30, New Delhi [“Ld. Cit(A)”] In Appeal No. Cit(A), Delhi-5/10256/2017-18 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 29.12.2017 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2015-16. 2. Brief Facts Of The Case Are That Assessee Company Has Filed Its Return Of Income On 28.09.2015, Declaring Total Income Of Inr 5,09,130/-. The Case Was Selected Under Limited Scrutiny & Notice U/S 143(2) Followed By Statutory Notices Issued U/S 142(1) Were Issued From Time To Time. In Response, Assessee Filed Submissions & Relevant Details Alongwith Evidences. The Ao Observed That The Assessee Issued 8,40,000 Equity Shares Of Inr 10/- Each At A Premium Of Inr 490/- Each & The Valuation Of Shares Was Done By Following Dcf Method. However, The Ao Rejected The Method Of Valuation Of Share Adopted By The Assessee & Re-Computed The Value Per Share At Inr 50.35 Per Share As Per Nav Method & Made Addition Of Differential Amount Of Inr 37,77,06,000/- U/S 56(2)(Viib) Of The Act.

Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153CSection 250Section 56(2)Section 56(2)(viib)

that assessee company has filed its return of income on 28.09.2015, declaring total income of INR 5,09,130/-. The case was selected under limited scrutiny and notice u/s 143(2) followed by statutory notices issued u/s 142(1) were issued from time to time. In response, assessee filed submissions

Tarique Akhlaque, Lucknow vs. ITO Ward 3(4), Sasaram

The appeal of the assessee is allowed for statistical purposes

ITA 512/PAT/2025[2015-2016]Status: DisposedITAT Patna28 Jan 2026AY 2015-2016

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.512/Pat/2025 (Assessment Year 2015-16) Tarique Akhlaque.…………………………… …………………....Appellant C/O Ahsan Khan, Flat No.6, Dashrath Bhawan, Rajeev Nagar, Jama Masjid Road, Munshipuliya, Indira Nagar, Lucknow, Uttar Pradesh-226016.. [Pan: Avxpa1802A] Vs. Ito, Ward-3(4), Sasaram……..……………..………………….…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Manab Adak, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 27, 2026 Date Of Pronouncing The Order : January 28, 2026

Section 142(1)Section 143(2)Section 144Section 250

individual and filed his return of Income declaring gross total income of Rs. 4,07,997/-. The case was selected under CASS for limited scrutiny. Consequently, I.T.A. No.512/Pat/2025 Tarique Akhlaque notices u/s 143(2) & u/s 142(1) were issued. However, no compliance was made by the assessee. Therefore, the Assessing

Bansilal Ramnath Agarwal Charitable Trust, Pune vs. CIT (Exemption), Pune

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

ITA 1357/PUN/2025[2020-21]Status: DisposedITAT Pune28 Jan 2026AY 2020-21

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Bansilal Ramnath Agarwal Charitable Trust Cit (Exemption), 251, Budhwar Peth, City Post Chowk, Vs. Pune Pune – 411002 Pan: Aaatb4383K (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 11-12-2025 Date Of Pronouncement : 28-01-2026 O R D E R Per R.K. Panda, V.P:

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR

Section 11Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 2(15)Section 263

total income at Nil. The return was processed u/s 143(1) of the Act by the CPC, Bangalore. Subsequently the case was selected for limited scrutiny through CASS for the reason “Trust executing contracts, providing professional services, earning commission income or rent (verification as per proviso to section ... incorrect and contrary to the assessment records. He submitted that the issue of transaction with the specified persons was specifically within the scope of limited scrutiny of payment to specified persons and was subjected to detailed and repeated examianation by the Assessing Officer. 15. Referring to the first notice issued

Shree Govind Property & Investments Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 5(1), Kolkata

In the result, the appeal filed by the assessee is dismissed

ITA 2166/KOL/2025[2018-2019]Status: DisposedITAT Kolkata28 Jan 2026AY 2018-2019

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 139(5)Section 142(1)Section 143(2)Section 143(3)Section 250

company had filed its return of income declaring total income of ₹1,60,39,320/- for AY 2018- 19. The case was selected for limited scrutiny under Computer Assisted Scrutiny Selection (in short 'CASS') for the reason "Large business loss set off against other heads of income." Accordingly, notices ... scrutiny assessment completed u/s 143(3) r.w.s. 143(3A) & 143(3B) of the Act. The case was selected for limited scrutiny on the specific issue of set-off of business loss, and after examining the submissions and documents filed, the returned income was accepted without variation. During the course

Ascon Infrastructure (India) Ltd., Kolkata vs. A.C.I.T., Circle - 9(1), Kolkata

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

ITA 2109/KOL/2025[2016-2017]Status: DisposedITAT Kolkata28 Jan 2026AY 2016-2017

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(2)Section 143(3)Section 234BSection 234CSection 250Section 271(1)(c)Section 43C

company and had filed the income tax return for AY 2016-17 showing total income of ₹47,32,200/-. The case was selected for limited scrutiny under Computer Assisted Scrutiny Selection (in short 'CASS'). During the year under consideration the assessee had sold properties and in respect of some

Shree Pragati Co Op Credit Society Limited, Rajkot vs. ITO, Ward-2(1)(1), Rajkot

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

ITA 693/RJT/2025[2020-21]Status: DisposedITAT Rajkot27 Jan 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Sanjay Pungalia Ld. CIT (DR)

Section 143(2)Section 143(3)Section 44ASection 68Section 80P

accounts which are duly audited u/s 44AB of the Income-tax Act, 1961. The case of the appellant was selected for scrutiny under CASS ‘Limited scrutiny’ on the ground of high Liabilities as compared to low income/receipts. It is further stated that low income (including exempt income and agricultural income ... sheet and large deduction under chapter VI-A of the Act. On which further clarification is required, therefore, the case has been selected for Limited scrutiny and clarification is required on following issues. ② ITA 693/RJT/2025 Shree Pragati CO OP Credit Society, Rajkot I. High Creditors/Liabilities II. High interest expenditure/finance costs

Chaturbhai K. Detroja (HUF), Morbi vs. Income Tax Officer Ward-1, Morbi

In the result, the appeal filed by the assessee is partly allowed in above terms

ITA 884/RJT/2024[2017-18]Status: DisposedITAT Rajkot27 Jan 2026AY 2017-18

Bench: Dr. Arjun Lal Saini

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 69A

return of income was processed u/s 143(1) of the Act. Later on, the case of the assessee was selected through CASS for "Limited Scrutiny" for verification of cash deposited during demonetization period for the year under consideration. Hence to verify the genuineness of source of cash deposits made