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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Neminath Developers, Mumbai vs. ITO, 42(1)(3)

In the result, the appeals of the assessee are allowed for statistical purposes

ITA 2194/MUM/2024[2018-19]Status: DisposedITAT Mumbai21 Aug 2024AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Sunil Kumar Singh, Jm

For Appellant: NoneFor Respondent: Shri Ashok Kumar Ambastha
Section 143(3)Section 144Section 270A

firm and filed the return of income for AY 2018-19 on 27.08.2018 declaring an income of Nil. The return was selected for limited scrutiny for verification of investments in immovable property. During the year under consideration the assessee has purchased property for Rs. 23,00,000/- whereas

Neminath Developers, Mumbai vs. ITO, 42(1)(3)

In the result, the appeals of the assessee are allowed for statistical purposes

ITA 2193/MUM/2024[2018-19]Status: DisposedITAT Mumbai21 Aug 2024AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Sunil Kumar Singh, Jm

For Appellant: NoneFor Respondent: Shri Ashok Kumar Ambastha
Section 143(3)Section 144Section 270A

firm and filed the return of income for AY 2018-19 on 27.08.2018 declaring an income of Nil. The return was selected for limited scrutiny for verification of investments in immovable property. During the year under consideration the assessee has purchased property for Rs. 23,00,000/- whereas

Kiran Ashok Desai, Mumbai vs. The PCIT Mumbai-19, Mumbai

In the result, Ground raised by the assessee is allowed and order passed by the Ld

ITA 1794/MUM/2024[2018-19]Status: DisposedITAT Mumbai21 Aug 2024AY 2018-19

Bench: Shri Amit Shukla & Shri Gagan Goyalkiran Ashok Desai, D-3, Triveni Building, 66 Walkeshwar Road, Maharashtra 400 066 Pan: Aabpd6275H ..... Appellant Vs. Pcit R. No. 617, 6Th Floor, Piramal Chamber, Lal Baug, Parel, Mumbai- 400 012 ..... Respondent

For Appellant: Shri Gunjan Kakkad, Ld. ARFor Respondent: Shri P. D. Chougule, Ld. DR
Section 143(3)Section 263Section 50CSection 56(2)Section 56(2)(x)

conditions stated under section 263 of the Act are not fulfilled; and 1.2.5 the subject matter of revisionary proceedings did not form part of limited scrutiny proceedings and the assessment order could not have been held to be 'erroneous and prejudicial to the interest of Revenue when ... could not have travelled beyond the issues forming subject matter of the 'limited scrutiny. 1.3 The Appellant prays that order passed under section 263 of the Act to be struck down as null and void ab initio. WITHOUT PREJUDICE TO GROUND 1: GROUND 2: THE ASSESSMENT ORDER PASSED

Mayur Global Private Limited, Jaipur vs. ITO Ward 1(3), Jaipur

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

ITA 906/JPR/2024[2015-16]Status: DisposedITAT Jaipur20 Aug 2024AY 2015-16

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

For Appellant: Shri S.L. Jain (Adv.) &For Respondent: Smt. Monisha Choudhary (Addl.CIT)
Section 10(34)Section 10(38)Section 14ASection 154Section 234A

30/09/2015 declaring total income at Rs.39,88,350/- which was processed u/s 143(1) of the IT Act, 1961. The case was selected for limited scrutiny under the 9 Mayur Global Pvt. Ltd. vs.ITO CASS. Accordingly, notice u/s 143(2) issued on 26/07/2016, fixing the case for hearing on 18/08/2016 ... 30/09/2015 declaring total income at Rs.39,88,350/- which was processed u/s 143(1) of the IT Act, 1961. The case was selected for limited scrutiny under the CASS. The AO disallowed Rs.5,44,649 /- u/s 14A of the I.T. Act. The assessee filed application u/s 154 before the Assessing

Jairaj Singh Solanki, Jaipur vs. ITO Ward 2(4), Jaipur

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

ITA 896/JPR/2024[2017-18]Status: DisposedITAT Jaipur20 Aug 2024AY 2017-18

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

For Appellant: Shri Shrawan Kumar Gupta (Adv.)For Respondent: Smt. Monisha Choudhary (Addl.CIT)
Section 115Section 115BSection 142(1)Section 143(2)Section 144Section 234Section 69A

assessee has filed his Return of income on 15.08.2017 declaring total income of Rs. 2,50,040/-. Thereafter, the case was selected for limited scrutiny through CASS for the reason "Credit Card Payments". Accordingly, notice u/s 143(2) was issued on 13.08.2018, which was duly served upon the assessee. Thereafter

Income Tax Officeer, Ward-2(2), Kota, Rawatbhata Road vs. Hitkari Vidyalaya Shakari Shiksha Samiti Limited, Bhatapara, Kota

Appeal of the revenue stands dismissed

ITA 646/JPR/2023[2020-21]Status: DisposedITAT Jaipur20 Aug 2024AY 2020-21
For Appellant: WORT Hl sie B/
Section 143(1)Section 143(2)Section 143(3)Section 80P(2)(d)

processed u/s 143(1) of the IT. Act 1961 on 22.02.2019 by the CPC at returned income. 5.1. The case was selected for limited scrutiny through CASS. A notice u/s 143(2) of the Act was issued to assessee under digital signature on ITA Nos. 645 & 646/JP/2023 ITO vs. Hitkari

Income Tax Officer, Ward-2(2), Kota, Rawatbhata Road vs. Hitkari Vidyalaya Shakari Shiksha Samiti Limited, Bhatapara, Kota

Appeal of the revenue stands dismissed

ITA 645/JPR/2023[2017-18]Status: DisposedITAT Jaipur20 Aug 2024AY 2017-18
For Appellant: WORT Hl sie B/
Section 143(1)Section 143(2)Section 143(3)Section 80P(2)(d)

processed u/s 143(1) of the IT. Act 1961 on 22.02.2019 by the CPC at returned income. 5.1. The case was selected for limited scrutiny through CASS. A notice u/s 143(2) of the Act was issued to assessee under digital signature on ITA Nos. 645 & 646/JP/2023 ITO vs. Hitkari

Sanjay Khanna, New Delhi vs. National E-Assessment Centre, Delhi

In the result, assessee’s appeal is allowed

ITA 2288/DEL/2024[2018-19]Status: DisposedITAT Delhi20 Aug 2024AY 2018-19

Bench: Shri Kul Bharatassessment Year: 2018-19

Section 142(1)Section 69A

above grounds are without prejudice to each other” 2. Facts, in brief, are that the case of the assessee was selected for limited scrutiny. The reason for taking up the case for scrutiny was credit-cards payments. The Assessing Officer issued notice u/s 142(1) of the Income

Hosahalli Jodinarasappa Lakshminarayana, Bengaluru vs. Income Tax Officer, Ward-3(3)(2), Bengaluru

In the result, appeal filed by the assessee is allowed

ITA 1218/BANG/2024[2017-18]Status: DisposedITAT Bangalore19 Aug 2024AY 2017-18

Bench: Shri George George Kassessment Year : 2017-18 Shri. Hosahalli Jodinarasappa Lakshminarayana, Vs. Ito, Asst. Director Pension Ground Floor, V V Tower, Ward – 3(3)(2), Podium Block, Dr. Ambedkar Veethi, Bengaluru. Bengaluru – 560 001. Pan : Adipl 5182 D Appellant Respondent Assessee By : Ms. Sunaina Bhatia, Ca Revenue By : Shri. Ganesh R. Gale, Standing Counsel For Department. Date Of Hearing : 14.08.2024 Date Of Pronouncement : 19.08.2024

For Appellant: Ms. Sunaina Bhatia, CAFor Respondent: Shri. Ganesh R. Gale, Standing Counsel for Department
Section 115BSection 143(2)Section 143(3)Section 234Section 250Section 69

Assessment Year 2017-18, the return of income was filed on 30.03.2018 declaring total income of Rs.6,12,910/-. The assessment was selected for limited scrutiny through CASS by issuance of notice under section 143(2) of the Act, to examine the source of cash deposits made during the demonetization

Sri. Police Gowdru Ramesh, Davangere vs. Income Tax Officer, Ward-1, Davangere

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

ITA 1124/BANG/2024[2017-18]Status: DisposedITAT Bangalore19 Aug 2024AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Years: 2017-18

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Shri Ganesh R Ghale, Standing Counsel for Dept
Section 115BSection 142(1)Section 69A

Appellant in his Bank accounts for the period from 1/4/2016 to 31/3/2017 when this assessment for the AY 2017-18 was selected for LIMITED SCRUTINY to verify the sources of cash deposits made in during the “DEMONITISATION PERIOD ie FROM 9/11/206 TO 31/12/2016 and the said action of the Learned ... CBDT INSTRUCTIONS Instruction No..20/2015 wherein it was instructed to all Assessing Officers that the Questionnaire under section 142(1) of the Act in 'Limited Scrutiny' cases shall remain confined only to the specific reasons/issues for which case has been picked up for scrutiny and further, the scope of enquiry

Income Tax Officer, Bkc, Mumbai vs. Idbi Staff Co-Operative Credit Society Ltd, Mumbai

Accordingly, all the grounds of the appeal of ld. AO are dismissed

ITA 1206/MUM/2024[2014-15]Status: DisposedITAT Mumbai19 Aug 2024AY 2014-15

Bench: Shri Prashant Maharishiassessment Year: 2014-15

For Appellant: Shri Mandar VaidyaFor Respondent: Shri R.R. Makwana, SR. DR
Section 142(1)Section 143(2)Section 143(3)Section 194A(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)Section 8O

financial assistance to its member. Assessee filed its return of income on 26.09.2014 declaring Rs. Nil as total income. The case was selected for limited scrutiny u/s 143(2) notice dated 01.092015 was issued. Notice u/s 142(1) was also issued on 07.09.2016. The ld. Assessing Officer looked

Smt Chandradevi Gautamchand Jain, Mumbai vs. The Income Tax Officer-30(1)(2), Mumbai

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

ITA 1104/MUM/2024[2015-16]Status: DisposedITAT Mumbai19 Aug 2024AY 2015-16

Bench: Shri Anikesh Banerjee & Shri Gagan Goyalsmt. Chandra Devi Gautam Chand Jain, Flat No. 1401, Bldg. 5, Raheja Classique Co-Op. Hsg. Soc. Ltd. Behind Infinity Mall, New Link Road, Andheri West, Mumbai-400 053 Pan: Aekpc6743G ..... Appellant Vs. Ito-30(1) (2) Room No. 505, C-505, Pratyaksh Kar Bhavan, Bandra Kurla Complex, Bandra East, Mumbai- 400 051 ..... Respondent

For Appellant: Shri Sanjay Parikh, Ld. ARFor Respondent: Shri H. M. Bhatt, Ld. DR
Section 143(3)Section 250Section 68

towards loan received from M/s. Tanaya Vincom Pvt. Ltd. without appreciating that that the addition was made by the AO in a limited scrutiny initiated to determine the source of investment in properties, which was duly explained by the appellant. 2) The learned CIT(A) erred in not appreciating that ... individual filed her return of income on 20.08.2015 declaring total income at Rs. 6,71,000/-. The case of the assessee was selected for “Limited Scrutiny” to examine the purchase of property. During the year under consideration the assessee invested in Flat in M/s. Runwal Projects Pvt. Ltd., Agricultural Land

Tarun Mohan Jani, Mumbai vs. The Assessment Unit, Income Tax Department

In the result, appeal filed by the assessee is allowed

ITA 475/MUM/2024[2020-21]Status: DisposedITAT Mumbai16 Aug 2024AY 2020-21

Bench: Shri Prashant Maharishiassessment Year: 2021-21 Tarun Mohan Jani To The Acit Flat No. 402, Plot No. 371/E-2, Circle (22) (1) Flora Avenue, Sandhu Garden Vs. Mumbai Junction, 10Th Road, Chembur, Mumbai-400071. Pan: Aaipj 4691 C (Appellant) (Respondent) Present For: Assessee By : Shri Bharat B Raichandani & Bhagrati Sahu Revenue By : Shri R.R. Makwana, Sr. Dr Date Of Hearing : 12.06.2024 Date Of Pronouncement : 16.08.2024

For Appellant: Shri Bharat B Raichandani and Bhagrati SahuFor Respondent: Shri R.R. Makwana, SR. DR
Section 143(2)Section 143(3)Section 50C(2)Section 55ASection 56(2)(x)

fact of the case is that assessee has filed his return of income on 29.08.2020 at Rs. 43,97,100/- which was selected for limited scrutiny for the reason that purchase value of property is less than the value of stamp authority. The assessee was granted opportunity of hearing

Navin Kalidas Patel, Ahmedabad vs. The Pr. CIT-3, Ahmedabad

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

ITA 109/AHD/2021[2015-16]Status: DisposedITAT Ahmedabad14 Aug 2024AY 2015-16

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 109/Ahd/2021 (िनधा"रण वष" िनधा"रण वष" / Assessment Year : 2015-16) िनधा"रण वष" िनधा"रण वष" बनाम बनाम/ बनाम बनाम Navin Kalidas Patel The Pr.Cit-3 802, Block –A, Status Ahmedabad Vs. Appartment, Opp. T. V. Tower, Drive-In-Road, Ahmedabad, Gujarat, 380054 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Achpp0215B (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri S. N. Soparkar, Sr. Advocate & Shri Parin Shah, A.R. ""यथ" क" ओर से/Respondent By : Shri Sudhendu Das, Cit. Dr Date Of Hearing 05/08/2024 Date Of Pronouncement 14/08/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: This Appeal Is Filed By The Assessee Against The Order Of The Principal Commissioner Of Income Tax, Ahmedabad-3, (In Short ‘The Pr. Cit’) Dated 29.03.2021 In Exercise Of His Revisionary Power Under Section 263 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The Assessment Year 2015-16. 2. The Brief Facts Of The Case Are That The Return Of Income For A.Y. 2015-16 Was Filed By The Assessee On 25.01.2016 Showing Total Income Of Rs.2,03,730/-. The Case Was Selected For Scrutiny

For Appellant: Shri S. N. Soparkar, Sr. Advocate &For Respondent: Shri Sudhendu Das, CIT. DR
Section 143(3)Section 263Section 68

properly examined the source of large investment made in the property by the assessee. According to the Ld. CIT.DR, the case was selected for limited scrutiny only to examine the large investment in property made by the assessee as compared to total income as disclosed. Therefore, it was incumbent upon

Mayur Nirmalkumar Jain, Ahmedabad vs. ITO, Ward-6(1)(3), Ahmedabad

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

ITA 676/AHD/2019[2014-15]Status: DisposedITAT Ahmedabad14 Aug 2024AY 2014-15

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

For Appellant: Shri Dhrunal Bhatt, A.RFor Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 133(6)Section 143(1)Section 143(2)Section 143(3)Section 68

return was processed under Section 143(1) of the Income Tax Act, 1961 ("the Act").The case was selected for limited scrutiny under CASS scheme. Accordingly, a notice under Section 143(2) was issued on 08.09.2015 and Mayur Nirmalkumar Jain vs. ITO Asst.Year –2014-15 - 3– served on the assessee

Virambhai Hargovanbhai Patel, Nagpur vs. Assistant Commissioner of Income Tax, Delhi

In the result appeal of the Revenue is dismissed

ITA 421/NAG/2022[2018-19]Status: DisposedITAT Nagpur14 Aug 2024AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Bhavesh MoryaniFor Respondent: Shri Abhay Y. Marathe
Section 143(2)Section 143(3)Section 234ASection 56(2)(x)

assesse filed return of income for the assessment year 2018-19 declaring total income at ` 7,33,700. The case was selected for limited scrutiny assessment under the E-assessment Scheme, 2019, to verify the issue on investment in immovable property. Accordingly, the Assessing Officer issued notices under section

Assistant Commissioner of Income Tax- 4(1)(1), Mumbai vs. Cvi Contact Lens India Private Limited, Mumbai

In the result, appeal of the assessee is allowed

ITA 1058/MUM/2024[2015-16]Status: DisposedITAT Mumbai14 Aug 2024AY 2015-16

Bench: Shri Anikesh Banerjee & Shri Gagan Goyal, Accountantacit 4 (1)(1), R. No. 678, Aayakar Bhavan, M. K. Road, Churchgate Mumbai-400 020 ...... Appellant Vs. Cvi Contact Lens India Pvt. Ltd. Office No. 3, 2Nd Floor, Vishnu Apartment, L.T. Road, Borivali West Pan: Aafcc3175N ..... Respondent

For Appellant: Shri H. M. Bhatt, Ld. DRFor Respondent: Shri Srihari Iyer, Ld. AR
Section 143(3)Section 154Section 234ASection 250

assessee company is engaged in the business of trading of contact lenses. The case of the assessee was selected for limited scrutiny through CASS. Case of the assessee was assessed at return income. Thereafter, the assessee filed an application u/s. 154 of the Act as the credit of self assessment

Jagriti Job Finder Private Limited, New Delhi vs. PCIT Central - 1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 2133/DEL/2024[2018-19]Status: DisposedITAT Delhi14 Aug 2024AY 2018-19

Bench: Ms.Madhumita Roy & Shri Avdhesh Kumar Mishram/S Jagriti Job Finder Vs. Pcit (Central) -1 Private Limited, 222, 2Nd New Delhi-110055 Floor Hemkunt Chamber, 89, Nehru Place, New Delhi – 110019 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabcj5974E Appellant .. Respondent

For Appellant: Sh. Ashwani Kumar &For Respondent: Sh. Sanjay Pandey
Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 14ASection 263

Rs.11,66,380/- which was processed under Section 143(1) of the Act on 05.11.2019. In fact, the case was taken up for limited scrutiny and notice under Section 143(2) dated 21.09.2019 followed by notice under Section 142(1) along with detailed questionnaire dated 16.01.2020 and further notice under

Shri Amardevi Nagari Sahakari Patsanstha, Pune vs. Income Tax Officer, Ward 9(3), Pune

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

ITA 1139/PUN/2024[2017-18]Status: DisposedITAT Pune13 Aug 2024AY 2017-18

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.1139/Pun/2024 "नधा"रण वष" / Assessment Year : 2017-18

For Appellant: NoneFor Respondent: Shri Rajesh Gawali
Section 142(1)Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

claimed deduction of Rs.28,10,447/- u/s.80P of the Income-tax Act, 1961 (hereinafter also 2 called ‘the Act’). The case was selected for Limited Scrutiny for the reason Large Deduction under Chapter VIA and Low income in comparison to High loans/advances/investment in shares appearing in Balance Sheet”. Notice u/s.142

Sajid Mowjee, Kolkata vs. ITO, Ward-4(1), Kolkata

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

ITA 207/KOL/2024[2017-18]Status: DisposedITAT Kolkata13 Aug 2024AY 2017-18

Bench: Shri Sonjoy Sarma, Jm & Shri Rakesh Mishra, Am Income Tax Officer, Sajid Mowjee Ward 4(1), Kolkata 3, Aster Court, Loudon Street Aaykar Bhavan, Vs. (Park Street), Kolkata-700 017 Kolkata-400 069 (Appellant) (Respondent) Pan No. Afvpm0023K

For Appellant: Shri Arvind Agarwal, ARFor Respondent: Shri Amitava Sen, DR
Section 143(2)Section 143(3)

income for the A.Y. 2017-18 by declaring total income of ₹33,42,150/-. Subsequently, the case of the assessee was selected for limited scrutiny under CASS (Computer Assisted Scrutiny Selection) in respect of credit card payment made by the assessee. The learned Assessing ITA No.207/ Kol/2024 Sajid Mowjee