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position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.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

Ladderup Finance Limited, Mumbai vs. Circle 14(1)(1), Mumbai

In the result the appeal filed by the assessee is allowed

ITA 7404/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Jan 2026AY 2015-16

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokarladderup Finance Circle 14(1)(1), Limited Mumbai 1St Floor Hallmark Vs. Aayakar Bhavan, Business Plaza, Mumbai-400 020 Gurunanak Hospital Road, Bandra (East), Mumbai- 400051 Pan/Gir No. Aaacl0882G (Applicant) (Respondent) Assessee By Shri Rushabh Mehta Revenue By Shri Surendra Mohan, Sr. Dr Date Of Hearing 20.01.2026 Date Of Pronouncement 27.01.2026

Section 10(34)Section 10(38)Section 111ASection 115JSection 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 271(1)(c)

return of income for the year under consideration on 29.09.2015, declaring a total income of Rs. 73,59,060/-.The case was selected for limited scrutiny under CASS for the following reasons: i. Large short term capital gains declared under section 111A, ii. Receipt of large value foreign remittance ... assessee challenged the validity of the assessment on the ground that the Assessing Officer travelled beyond the scope of limited scrutiny and other disallowances as detailed above. 4.6. The assessee contended that adequate interest-free funds were available to cover investments, investments were largely strategic in nature, no further expenditure

J.B Petit High School for Girls, Mumbai vs. CIT(Exemption), Mumbai

In the result, the Assessee’s appeal is allowed

ITA 4667/MUM/2025[2022-23]Status: DisposedITAT Mumbai27 Jan 2026AY 2022-23

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2022-23

For Appellant: Shri Sukhsagar Sayal, Ld. ARFor Respondent: Shri Vivek Perampura, (CIT DR

Section 143Section 263

Petiti High School for Girls 2. In the instant case, the case of the Assessee was selected for limited scrutiny on the following issue: “The Assessee has large amount of income accumulated or set apart by trust” The Assessing Officer examined such issue and vide assessment order dated 23.02.2024 under ... income of Rs.7,73,39,821/-. The Assessee further submitted before the Ld. PCIT that, since the case of the Assessee was selected for ‘limited scrutiny’ and resulted into making the assessment under limited scrutiny and therefore, its scope cannot be expanded under the provisions of Section

ITO Ward - 20(3), New Delhi vs. Quetzal Exim Pvt Ltd, New Delhi

In the result, the appeal filed by the Department of Revenue is allowed

ITA 717/DEL/2020[2016-17]Status: DisposedITAT Delhi27 Jan 2026AY 2016-17

Bench: Shri S Rifaur Rahman & Shri Vimal Kumar

Section 142(1)Section 143Section 143(2)Section 250(6)Section 56Section 56(2)

case are that assessee company filed its return of income on 17.10.2016 declaring total income of Rs.90,780/-. The case was selected for under limited scrutiny through CASS for verification of investment and also for verification of funds received in the form of share premium are from disclosed sources

Emerald Gems Private Limited, Surat vs. Income Tax Officer, Ward 1(1)(2), Surat

In the result, the appeal of the assessee is allowed

ITA 956/SRT/2025[2017-18]Status: HeardITAT Surat23 Jan 2026AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 115BSection 145Section 250Section 68

diamonds. It filed its return of income for AY 2017-18 declaring total income of Rs.4,25,100/-. The case was selected for limited scrutiny under CASS for verification of cash deposits during the demonetization period from 09.11.2016 to 30.12.2016. During this period, the assessee deposited cash aggregating to Rs.35

Ramanbhai P. Viradiya HUF, Surat vs. ITO, Ward 3(3)(1), Surat

In the result, the appeal of the assessee is allowed

ITA 556/SRT/2025[2017-18]Status: HeardITAT Surat23 Jan 2026AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra Kamble

For Appellant: Shri Mehul Shah, C.AFor Respondent: Shri Ashish Kumar, Sr. D.R

Section 68

assessment year 2017-18. 2. The assessee has shown agricultural income at Rs. 1,87,925/-. The assessee’s case was selected for limited scrutiny to verify the cash deposit during demonetization period. The Assessing Officer made addition of Rs. 12,50,000/- deposited in the Allahabad Bank and added

Pragjibhai Parshotambhai Patel, Na vs. Arivs.Income Tax Officer, Ward-4, Navsari

In the result, the appeal of the assessee is allowed

ITA 858/SRT/2024[2014-15]Status: HeardITAT Surat23 Jan 2026AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 250Section 44ASection 50C

engaged in business of trading in agricultural land/plots and declared income on presumptive basis u/s 44AD of the Act. The case was selected for limited scrutiny. During assessment proceedings, the Assessing Officer made the impugned additions, which were confirmed by the Ld. CIT(A). 4. We have heard the rival

Shri Narayandas Ramdas Sevak Shakari Patsanstha Maryadit, Pune vs. The ITO Ward-14(5), Pune

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

ITA 2862/PUN/2025[2020-21]Status: DisposedITAT Pune23 Jan 2026AY 2020-21

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Sarang GudhateFor Respondent: Shri Manish Mehta, Addl.CIT

Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

investments to earn income. The assessee filed its return of income on 23.07.2018 declaring Nil income. The case of the assessee was selected for limited scrutiny assessment on the following issues: S.No. Issues i. Investments/Advances/Loans ii. Deduction from total income under Chapter VI-A 3. The Assessing Officer completed

Shri Narayandas Ramdas Sevak Shakari Patsanstha Maryadit, Pune vs. The ITO Ward-14(5), Pune

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

ITA 2861/PUN/2025[2018-19]Status: DisposedITAT Pune23 Jan 2026AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Sarang GudhateFor Respondent: Shri Manish Mehta, Addl.CIT

Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

Vrahatakar Sahakari Sanstha Maryadit Amletha, Amletha vs. ITO-1, Ratlam

Appeal is allowed for statistical purpose

ITA 379/IND/2025[2017-18]Status: DisposedITAT Indore22 Jan 2026AY 2017-18

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 139Section 143(2)Section 143(3)Section 250(6)Section 80P

pleased to: 1. Quash the assessment order u/s 143(3) as void ab initio for invalid 143(2) notice and breach of limited scrutiny instructions. 2. Allow full deduction u/s 80P(2)(a)(i), 80P(2)(iv), 80P(2)(c)(ii), 80P(2)(d) as claimed. 3. Delete the entire

Mrs. Lalita Ramesh Porwal, Lonavla vs. ITO Ward-9(5), Pune

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

ITA 3023/PUN/2025[2017-18]Status: DisposedITAT Pune22 Jan 2026AY 2017-18

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.3023/Pun/2025 Assessment Year : 2017-18

For Appellant: Shri Dipesh PorwalFor Respondent: Date of hearing

Section 143(3)Section 250

Lalita Ramesh Porwal return filed for A.Y. 2017-18 furnished on 06.02.2018. After the case being selected for Limited Scrutiny under CASS for examining source of cash deposit during the demonetization period valid statutory notices were served upon the assessee and has been asked to explain the source of cash

Satara Zilla Dak Karmachari Sahakari Pathsanstha, Near Suruchi Banglow, Shukrawar Peth, Satara vs. Assessing Officer Ward 2, Aaykar Bhawan, Manjunath Manor, Pawai Naka, Satara

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

ITA 2829/PUN/2025[2018-19]Status: DisposedITAT Pune22 Jan 2026AY 2018-19

Bench: Shri Manish Boradआयकर अपील सं. / Ita No.2829/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Satara Zilla Dak Karmachari Vs. Ito, National E- Sahakari Pathsanstha, Assessment Centre, 117/B, Near Suruchi Delhi. Banglow, Shukrawar Peth, Satara- 415002. Pan : Aapas2980K Appellant Respondent Assessee By : Shri Rajkumar Doshi Revenue By : Shri Shashank Ojha (Virtual) Date Of Hearing 13.01.2026 : Date Of Pronouncement : 22.01.2026 आदेश / Order Per Manish Borad, Am: This Appeal Filed At The Instance Of Assessee Is Directed Against The Order Of Ld. Cit(A)/Nfac Dated 24.09.2025 Which Is Arising Out Of The Assessment Order U/S 144 R.W.S. 143(3A) & 143(3B) Of The Act For Assessment Year 2018-19 Framed On 12.04.2021 By The Ito, National E-Assessment Centre, Delhi. 2. The Effective Grounds Of Appeal Raised By The Assessee Is Against The Disallowance Of Deduction Of Rs.43,54,979/- Claimed U/S 80P Of The Act. In The Grounds Of Appeal, The Assessee Also Stated That In Its Own Case For A.Y. 2020-21, Ld. Cit(A) Has Allowed The Deduction U/S 80P Of The Act. Further, The Request Has Been Made

For Appellant: Shri Rajkumar DoshiFor Respondent: Shri Shashank Ojha (Virtual)

Section 143(2)Section 144Section 80PSection 80P(2)(a)

declaring income of Rs.1,21,880/- after claiming deduction u/s 80P(2)(a)(i) at Rs.43,54,979/-. Case selected for limited scrutiny for examining the investments/advances/loans and deduction under Chapter VI-A. Statutory notices u/s 143(2) and 142(1) were duly served upon the assessee. I note that

Income Tax Officer Ward 22.1.1, Mumbai vs. Antara Tushar Motiwala, Mumbai

ITA 3662/MUM/2025[2017-18]Status: DisposedITAT Mumbai22 Jan 2026AY 2017-18

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar

Section 115BSection 133(6)Section 142(1)Section 143(1)Section 143(3)Section 250Section 68

declaring total income of Rs. 19,05,920/-. The return was processed under section 143(1) of the Act. The case was selected for limited scrutiny under CASS on the issue of large increase in capital during the year. During the course of assessment proceedings, the Assessing Officer noticed

Vimal Alloys Private Limited, Mandi Gobindgarh, Punjab vs. Jao the Deputy Commissioner of Income Tax Circle, Patiala, Punjab

ITA 890/CHANDI/2025[2016-2017]Status: DisposedITAT Chandigarh21 Jan 2026AY 2016-2017

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Vipen Sethi, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 143(1)Section 147Section 148Section 151Section 69A

needs to specify the category of the scrutiny selected under CASS (Computer Aided Scrutiny Selection) as to whether, it is a limited scrutiny, manual scrutiny or Complete Scrutiny Assessment. In the case of the assessee the instruction of CBDT referred above have not been followed, for which, we have taken

Vikram Sugriv Kale, Osmanabad vs. Income Tax Officer Ward 1, Nanded

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

ITA 2833/PUN/2025[2018-19]Status: HeardITAT Pune21 Jan 2026AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Vikram Sugriv Kale Ito, Ward 1, Nanded Vikram Stoves & Fabricators, Vs. Digvijay Construction, A 37, Midc, Osmanabad – 413501 Pan: Agapk8979L (Appellant) (Respondent) Assessee By : Shri Rohit S Tapadiya Department By : Shri Manish Mehta, Addl.Cit Date Of Hearing : 21-01-2026 Date Of Pronouncement : 21-01-2026 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Rohit S TapadiyaFor Respondent: Shri Manish Mehta, Addl.CIT

Section 143(3)Section 271ASection 275

contractor-ship in irrigation department. The assessee filed his return of income declaring total income of Rs.52,02,470/-. The case was selected for limited scrutiny on the issue of verification of genuineness of expenses. The Assessing Officer passed the order u/s 143(3) r.w.s

Qadeer Ahmed Mohammed, Hyderabad vs. DCIT., Circle-1(1), Hyderabad

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

ITA 768/HYD/2025[2020-21]Status: DisposedITAT Hyderabad21 Jan 2026AY 2020-21

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

Section 142(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 249(2)Section 68

Profits & Gains from business or profession”. The assessee is mainly engaged in the business of freight transport by road. The case was selected for limited scrutiny under CASS on the reasons of substantial increase in agricultural income as compared to the preceding year, agricultural income (risk analysis), and large agricultural

Manoj Kumar Chowrah, Hyderabad vs. Income Tax Officer, Ward-4(1), Hyderabad

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

ITA 1614/HYD/2025[2017-18]Status: DisposedITAT Hyderabad21 Jan 2026AY 2017-18

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 69A

return of income for the assessment year 2017-18 on 30.08.2017, declaring total income of Rs. 8,72,110/-. The case was selected for limited scrutiny under CASS to verify the cash deposits during the year and investment in sale / purchase of immovable property. During the course of assessment

Konatham Kotireddy, Warangal vs. Income Tax Officer, Ward - 1, Warangal

In the result, appeal of the Assessee is allowed

ITA 1464/HYD/2025[2017-18]Status: DisposedITAT Hyderabad21 Jan 2026AY 2017-18

Bench: Shri Vijay Pal Rao

For Appellant: CA A VamseedharFor Respondent: MS P Sumitha, Sr. AR

Section 143(3)Section 145(3)Section 271BSection 69A

gross miscarriage of justice. - 7. That the assessment and the appellate order stand vitiated as the Assessing Officer travelled beyond the scope of "limited scrutiny" (restricted to cash deposits), in contravention of CBDT Instruction No.5/2016 dated 14.07.2016, and proceeded to make additions dehors jurisdiction, rendering the assessment null and vold ... filed his return of income for the year under consideration on 19.12.2017 declaring total income of Rs.6,04,030/-. The case was selected for limited scrutiny examination of cash deposits during the year under consideration. However, the Assessing Officer has gone beyond the scope of limited scrutiny while completing

Rakesh Kumar Agarwal, Mancherial vs. Income Tax Officer, Ward-1, Mancherial

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

ITA 1442/HYD/2025[2017-18]Status: DisposedITAT Hyderabad21 Jan 2026AY 2017-18

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 69A

filed his return of income for assessment year 2017-18 on 06.03.2018 admitting income of Rs. 2,97,830/-. The case was selected for limited scrutiny and during the course of assessment proceedings, the A.O. noticed that, the assessee has made cash deposit into bank accounts maintained with ICICI Bank

DCIT, Mumbai vs. Sahyadri Agencies Limited, Moothedath House Arikanniyur

ITA 4257/MUM/2025[2018-19]Status: DisposedITAT Mumbai21 Jan 2026AY 2018-19

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 143(2)Section 14ASection 36(1)(iii)

I.T.A. No. 4257/Mum/2025 IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER) & SHRI GIRISH

New Star System Solution Private Limited, Delhi vs. DCIT, Circle-18(2), Delhi

In the result, appeal of the Assessee is accordingly allowed

ITA 3585/DEL/2025[2015-16]Status: DisposedITAT Delhi21 Jan 2026AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 142(1)Section 143(2)Section 250Section 36(1)Section 36(1)(iii)

Detail of Notices issued / Assessment framed SN Notice u/s Date Issued by 1. Intimation to 12.04.2016 DCIT-Circle 18(1),Delhi Limited Scrutiny 143(2) 2. 143(2) 19.09.2016 -----------do---------- 3. All 142(1) on different dates -----------do---------- 4. Asstt. Order 31.12.2016 -----------do---------- Copy of above notices attached with