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“complete scrutiny”

Assessment ProceduresSection 143(3)Section 143(3)2,579 judgments

The decision most relied on for complete scrutiny is Dr. C. Balakrishnan Nair v. CIT (237 ITR 70), cited in 42 judgments on BharatTax.

Leading authorities on complete scrutiny

Dr. C. Balakrishnan Nair v. CIT
237 ITR 70 · 1999 · High Court
42
citing judgments

A restraint order under Section 132(3) cannot be passed solely on the ground that scrutiny of documents or assets could not be completed during a search, as the search process must be continuous. Additionally, Section 158BC (Chapter XIV-B) cannot be invoked if there is no violation of the Income-tax Act, such as when valid exemptions are claimed.

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.

70 ITD 214 11. Jain Bharat Tanners Vs. CIT (Mad) 264 ITR 673 12. Ashok Leyland Ltd. v. CIT(Mad)
101 ITD 495 · 2006 · ITAT
35
citing judgments

An assessment order is erroneous and prejudicial to the interest of the revenue if the Assessing Officer fails to conduct necessary inquiries or investigate facts when circumstances warrant it, demonstrating a lack of complete scrutiny. This failure to act as an investigator and not just an adjudicator can trigger revision under Section 263.

ITO v. V.R. Global Energy (P.) Ltd.
113 Taxmann.com 31 · 2020 · Supreme Court
21
citing judgments

Share capital and share premium cannot be treated as unexplained cash credits under section 68 of the Income Tax Act, especially when cash did not pass at any stage and entries made a complete round. The Supreme Court dismissed the Revenue's appeal against this view.

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.

2004) 267 ITR 698 (Raj) 5. Paul Mathews & Sons v CIT (2003) 263 ITR 101 (Ker) 6. CIT v. Arvind Jewellers
253 ITR 124 · 2002 · High Court
13
citing judgments

A revisionary order under Section 263 is invalid if it is based on the same facts and involves extensive enquiry after the assessment proceedings were completed, implying a lack of application of mind during the original assessment.

Bakshi Vikram Vikas Construction Co. P. Ltd. v. DCIT
131 CTR 203 · 1996 · High Court
11
citing judgments

The Project Completion Method (PCM) for accounting is a recognized and scientifically sound method that has judicial approval for real estate businesses, allowing profit or loss to be recognized only upon project completion.

CIT (2003) 263 ITR 101 (Ker) 6. CIT v Arvind Jewellers (2003) 259 ITR 502 (Guj) 7. CIT v. Hastings Properties
247 ITR 555 · 2001 · High Court
11
citing judgments

A Principal Commissioner (PCIT) cannot assume jurisdiction under Section 263 merely because the Assessing Officer's (AO) view is not acceptable, if the AO has made due enquiries and taken a plausible view.

Judgments citing complete scrutiny

7 Horses Hospitality LLP, Jaipur vs. Income Tax Officer, Ward 1(1) Jaipur, Jaipur

In the result, all the three appeals of the assessee in ITA No

ITA 332/JPR/2023[2019-20]Status: DisposedITAT Jaipur13 Sept 2023AY 2019-20

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

For Appellant: Shri Sharwan Kumar GuptaFor Respondent: Ms. Monisha Choudhary, Addl. CITa
Section 143(1)Section 143(1)(a)Section 36(1)(va)Section 43B

WARD 1 (1), JAIPUR for scrutiny selection and such cases are called Limited Scrutiny cases and only the remaining returns are taken up for complete scrutiny u/s 143(3) of the Act. 13.2 Meaning thereby, that exercise of power under sub-section (2) of section 143 of the Act leading

Apm Industries Ltd, Bhiwadi, Alwar vs. Deputy Commissioner of Income Tax, Central Circle - 1, Alwar

In the result, appeal of the assessee is allowed

ITA 203/JPR/2023[2018-19]Status: DisposedITAT Jaipur12 Sept 2023AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. No. 203/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2018-19 APM Industries Ltd. SP-147, Industrial Area Bhiwadi, Alwar cuke Vs. Deputy Commissioner of Income Tax Central Circle-01, Alwar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AACCA 5114 G vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. S. L. Poddar jktLo dh vksj ls@ Revenue by : Smt. Monisha Choudhary (JCIT) a l

For Appellant: Sh. S. L. PoddarFor Respondent: Smt. Monisha Choudhary (JCIT) a
Section 142(1)Section 143(2)Section 143(3)Section 194ASection 263Section 40Section 40A(7)

year under consideration, the assessee filed return of income declaring total income of Rs.10,31,88,100/- on 31/10/2018. The case was selected for complete scrutiny and notice u/s 143(2) was issued on 23/09/2019. As per the assessment order, the main issues for examination were – (i) Duty Drawback ... heard who has relied on the findings of the lower authorities and submitted that the case of the assessee was selected for complete scrutiny flagging the three issues to be examined. In addition, the ld. PCIT flagged mismatch in the records and the order of the ld. AO is silent

Abhinandan Kedia, Janjgir-Champa vs. Principal Commissioner of Income Tax, Raipur-1, Raipur

In the result appeal of the assessee is allowed in terms of our observations herein above

ITA 174/RPR/2023[2018-19]Status: DisposedITAT Raipur11 Sept 2023AY 2018-19

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.174/Rpr/2023 िनधा"रण वष" /Assessment Year: 2018-19

For Appellant: Shri S.R.Rao, AdvFor Respondent: Shri Debashish Lahiri, CIT DR
Section 143(2)Section 143(3)Section 263

accepted as per Return. 4. The ld. Pr.CIT issued notice u/s 263 on 22/02/2023 on the grounds that (a) the case was selected for complete scrutiny and (b) ld. A.O. allowed the claim of depreciation for addition to different block of assets without verification. (c) 5. In response appellant filed ... aside the assessment order on the observations that it is mentioned in first para of said order that the case was selected for complete scrutiny. The appellant has furnished copies of bills and supporting evidences, his contention has been verified and apparently, prima-facie, no adverse inference is drawn. However

Vishal Diamonds Private Limited, Mumbai vs. Principle Commissioner of Income Tax-5, Mumbai

In the result, the appeal filed

ITA 878/MUM/2023[2018-19]Status: DisposedITAT Mumbai06 Sept 2023AY 2018-19

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2018-19 Vishal Diamonds Pvt. Ltd., The Pcit-5, 11Th Floor, The Plaza, Hughes Room No. 515, Road, 55, Gamdevi, Vs. Aayakar Bhavan, Mumbai-400007. Maharshi Karve Road, Mumbai-400020. Pan No. Aaacv 2799 Q Appellant Respondent

For Appellant: Mr. Hariom TulsiyanFor Respondent: Mr. Ankush Kapoor, CIT-DR
Section 14ASection 263

during the assessment not been examined properly Us 13316) of the Act during the assessment proceedings though case was selected for complete scrutiny and these proceedings though case was selected for complete scrutiny and these proceedings though case was selected for complete scrutiny and these parties were nöt examined under

Hireright Ltd, Uk vs. ACIT, Circle 2(1)(1), International Taxation, New Delhi

In the result, the appeals of the assessee for both the AYs 2019-20

ITA 373/DEL/2023[2020-21]Status: DisposedITAT Delhi06 Sept 2023AY 2020-21

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2020-21 & Asstt. Year: 2019-20

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 143(3)Section 234ASection 234DSection 270A

case of the assessee for both the AYs was selected for complete scrutiny under CASS. Statutory notices along with detailed questionnaire were issued through electronic mode from time to time. In response thereto the assessee filed submissions as per electronic order sheet which has been placed on record. After perusing

Gunjan Bhageria, New Delhi vs. ACIT, New Delhi

ITA 909/DEL/2022[2017-18]Status: DisposedITAT Delhi06 Sept 2023AY 2017-18

Bench: Shri N. K. Billaiya & Shri Anubhav Sharma

Section 127Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 263Section 285B

assessee has filed return of income for the A.Y. 2017-18 declaring an income of Rs. 18,93,020/- which was selected for 2 complete scrutiny through CASS/CPC and the following assessment order u/s 143(3) dated 14.12.2019 was passed; “The assessee e-filed return of Income for the Assessment ... processed under section 143(1) of the Income-tax Act, 1961 (hereinafter, the Act’) electronically at returned income. The case was selected for complete Scrutiny through CASS/CPC as per guidelines/ procedure for selection of cases for complete scrutiny. 2. Accordingly, statutory notice under section 143(2) was issued from ITBA

Hireright Limited, London vs. ACIT, Circle 2(1)(1), Int. Tax, New Delhi

In the result, the appeals of the assessee for both the AYs 2019-20

ITA 1884/DEL/2022[2019-20]Status: DisposedITAT Delhi06 Sept 2023AY 2019-20

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2020-21 & Asstt. Year: 2019-20

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 143(3)Section 234ASection 234DSection 270A

case of the assessee for both the AYs was selected for complete scrutiny under CASS. Statutory notices along with detailed questionnaire were issued through electronic mode from time to time. In response thereto the assessee filed submissions as per electronic order sheet which has been placed on record. After perusing

M/S Eternal Heart Care Centre & Research Institute Pvt. Ltd., 3A, Jagatpura Road, Near Jawahar Circle, Jaipur vs. PCIT, Jaipur-2, Jaipur

In the result, appeal filed by the assessee is allowed

ITA 263/JPR/2023[2018-19]Status: DisposedITAT Jaipur06 Sept 2023AY 2018-19

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

For Appellant: Shri Yogesh Parwal, CA &For Respondent: Shri James Kurian, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 14ASection 263Section 271A

assessee is running a multi-specialty hospital. It filed the return on 03.10.2018 at Nil income. The case of the assessee was selected for complete scrutiny with one of the reason being ’investments’. The assessee filed reply to the AO on 07.10.2019 submitting that the company has parked surplus funds ... during the year under consideration with reference to investment in such mutual funds. We note that the case of the Assessee was selected for complete scrutiny where one of the reasons was investments/advances/loans’. Further the AO in notice u/s 142(1) dt. 09.12.2020 in course of assessment proceedings enquired about

Aman Growth Fund Pvt Ltd, New Delhi vs. Pr.CIT, Delhi

In the result, the appeal of the assessee is allowed

ITA 659/DEL/2021[2015-16]Status: DisposedITAT Delhi31 Aug 2023AY 2015-16

Bench: Sh. G.S.Pannu, Hon’Ble & Sh.Anubhav Sharmaita No. 659/Del/2021, A.Y. 2015-16 M/S. Aman Growth Fund Vs. Pr. Cit(Central), Private Limited Delhi-2 L-4, Green Park Extension New Delhi Pan : Aaaca0525B Appellant Respondent

Section 142(1)Section 143Section 143(3)Section 263Section 56Section 56(2)(viib)

make the inquiries and based on information available. Ld. AO should have expanded the scope of assessment to convert the limited scrutiny into complete scrutiny. Accordingly, Ld. PCIT had directed the ld. AO to make fresh assessment keeping in mind the observations. 3. At the time of hearing

Nanak Chand & Co., U.P vs. Pr. CIT, Gzbd

In the result, the appeal of the assessee is allowed

ITA 904/DEL/2022[2017-18]Status: DisposedITAT Delhi30 Aug 2023AY 2017-18

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kedia

For Appellant: Shri S.K. Goyal, CAFor Respondent: Shri Subhra Jyoti Chakraborty, CIT-DR
Section 143(3)Section 263

whereby the returned income was assessed without any modification. As per the assessment order, the return of assessee was selected under complete scrutiny with verification of cash deposits during demonetization period as central issue. 4. After the completion of the assessment, in exercise of the powers conferred under Section ... filed on 22.10.2017 declaring total income of Rs.1,75,930/- Later on the case was selected for complete scrutiny under CASS with reasons "abnormal increase in cash deposits during demonetization period as compared to pre- demonetization period ". The ITO, Ward-2(3)(3), Bulandshahr completed assessment order

Yogesh Kumar Agarwal, Saharanpur vs. ITO, Ward-3(3)(5), Saharanpur

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

ITA 105/DEL/2023[2018-19]Status: DisposedITAT Delhi29 Aug 2023AY 2018-19

Bench: Shri Shamim Yahya & Ms. Astha Chandraasstt. Year: 2018-19

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Shri Amit Katoch, Sr. DR
Section 143(2)Section 143(3)Section 68

income of Rs. 5,00,000/- from business of retail sale of other product NEC trading of shares and securities. It was selected for complete scrutiny under CASS. During assessment proceedings notice under section 143(2) of the Income Tax Act, 1961 (the “Act”) was served upon the assessee through

D V Properties Pvt. Ltd., Surat vs. Pr. Commissioner of Income Tax - 1, Surat

In the result, appeal filed by the assessee is partly allowed to the extent indicated above

ITA 121/SRT/2023[2018-19]Status: DisposedITAT Surat29 Aug 2023AY 2018-19

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.121/Srt/2023 Assessment Year: (2018-19) (Physical Hearing) D. V. Properties Pvt. Ltd., Vs. The Pcit - 1, 748-749, Golden Plaza Market, Surat. Ring Road, Surat – 395002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaacd8392B (Appellant) (Respondent) Ms Chaitali Shah, Ca Appellant By Shri Ashok B. Koli, Cit(Dr) Respondent By Date Of Hearing 19/07/2023 Date Of Pronouncement 29/08/2023

Section 143(3)Section 263Section 37(1)Section 43B

filed its return of income for A.Y. 2018-19, on 17.11.2018, declaring total income at Rs. Nil. The assessee`s case was selected for complete scrutiny under E-Assessment Scheme, 2019, having specific issue of examination as high ratio of refund to TDS. The scrutiny assessment under section

M/S Parth Developers, Dhar vs. The PCIT -1, Indorer

In the result, appeal of assessee is allowed

ITA 419/IND/2022[2015-16]Status: DisposedITAT Indore28 Aug 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Parth Developers Pr. Cit-1 Manawar Dist. Indore Vs. Dhar (Appellant / Assessee) (Respondent/ Revenue) Pan: Aalfp 4509 N Assessee By Shri Milind Wadhwani, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 22.06.2023 Date Of Pronouncement 28.07.2023

Section 142(1)Section 143Section 143(3)Section 263Section 43C

subject matter of limited scrutiny while passing the assessment order. The answer to this question is certainly not without converting the limited scrutiny into complete scrutiny. Therefore, in case the AO proceeded within the scope of limited scrutiny and not taken up any issue beyond the scope of limited scrutiny ... confined only to issues under Limited Scrutiny and questionnaires, enquiry. investigation etc. would be restricted to such issues. Only upon conversion of case to 'Complete Scrutiny' after following the procedure outlined above, the AO may examine the additional issues -besides the issue(s) involved in 'Limited Scrutiny'. The AO shall

Girnar Software Private Limited, 6Th Floor, Jaipur Textile Market, B-2, Near Model Town, Malviya Nagar, Jaipur vs. PCIT – 2, Jaipur, New Central Revenue Building

In the result, the appeal of the assessee is allowed

ITA 330/JPR/2023[2018-19]Status: DisposedITAT Jaipur28 Aug 2023AY 2018-19

Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri PC Parwal, CAFor Respondent: Shri Arvind Kumar (CIT)
Section 142(1)Section 143(2)Section 14ASection 263

customers. Apart from these it also provides a slew of services – interest marketing and technology solutions. The case of the assessee was selected for complete scrutiny under CASS. Accordingly statutory notice under section 143(2) was issued on 22.09.2019 which was duly served upon the assessee through ITBA portal. Thereafter ... assessee submitted his written submissions as under :- “ In the submitted that the case of the Appellant was selected for Complete Scrutiny under the E-assessment Scheme 2019 and a notice 5 Girnar Software Pvt. Ltd., Jaipur. dated 22 September 2019 was issued under section

Columbus Overseas LLP, 16, Raja Park, Adarsh Nagar, Jaipur vs. Principal Commissioner of Income Tax-1, Jaipur, New Central Revenue Building, Bhagwan Das Road

In the result, appeal of the assessee is dismissed

ITA 196/JPR/2023[2018-19]Status: DisposedITAT Jaipur28 Aug 2023AY 2018-19

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

For Appellant: Shri S.L. Poddar (Adv.)For Respondent: Shri Ajey Malik (CIT) a
Section 142(1)Section 143(2)Section 143(3)Section 263

assessee for the assessment year 2018-19 on 18.10.2018 declaring total income of Rs. 7,11,130/-. Subsequently, the case was selected for complete scrutiny through CASS and accordingly notice u/s 143(2) of the Act dated 22.09.2019 was issued 3 Columbus Overseas LLP electronically and served upon the assessee ... dated 27.11.2020 along with questionnaire was also issued online and served upon the assessee. The case was selected from complete scrutiny assessment under the E-assessment Scheme, 2019 on the following issues:- 1. Income from Real Estate Business. 2. Contract Receipt or fees 3. Unsecured loans On perusal

DCIT, Cir-3(3)(1), Mumbai vs. M/S. Villa Mode Export (India) Pvt Ltd, Mumbai

In the result, the appeal filed by the Revenue is allowed for In the result, the appeal filed by the Revenue is allowed for In the result, the appeal filed by the Revenue is allowed for statistical...

ITA 1444/MUM/2023[2016-17]Status: DisposedITAT Mumbai25 Aug 2023AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 Dy. Cit, Circle-3(3)(1), M/S Villa Mode Exports (India) Pvt. Room No. 609, Aayakar Ltd., Vs. Bhavan, M.K. Road, 1023, 10Th Floor, Summit Business Churchgate, Bay, Near W.E.H. Metro Station, Mumbai-400020. Chakala Midc S.O., Mumbai-400093. Pan No. Aaacv 7010 N Appellant Respondent

For Appellant: Mr. M SubramnianFor Respondent: Mr. Ujjawal Kumar Chavan, DR
Section 144Section 68

been selected for complete Please note that your case has been selected for complete Please note that your case has been selected for complete scrutiny and subsequent details were called for from you after y and subsequent details were called for from you after y and subsequent details were called

Rajendra Kumar Agrawal, Raipur vs. Principal Commissioner of Income Tax, Raipur-1, Raipur

In the result, the appeal of the assessee is allowed

ITA 130/RPR/2023[2018-19]Status: DisposedITAT Raipur24 Aug 2023AY 2018-19

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.130/Rpr/2023 निर्धारण वर्ष /Assessment Year: 2018-19 Rajendra Kumar Agrawal Vs Principal Commissioner Of Income Gandhi Chowk Tax, Raipur-1 Neora, Raipur (C.G.) 493114 Pan No. Acipa 5919L (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्धारितीती की ओर से /Assessee By : Shri Praveen Goyel, Ca राजस्व की ओर से /Revenue By : Smt. Ila M. Parmar, Cit-Dr सुनवाई ाई की तारीख / Date Of Hearing : 21/08/2023 घोषणाणा की तारीख/Date Of Pronouncement : 24 /08/2023 आदेश / O R D E R Per Arun Khodpia, Am : The Captioned Appeal Is Filed By The Assessee Against The Order Passed By The Ld. Principal Commissioner Of Income Tax, Raipur-1, Dated 16.03.2023 U/S 263 Of The Income Tax Act, 1961. The Grounds Of The Appeal Raised By The Assessee Are As Under: “ 1. That On The Facts & In The Circumstances Of The Case & In Law, The Order Passed By Id. Pr. Cit-1, Raipur U'S 263 Of The Act Dated 16/03/2023 Is Illegal & Void- Ab-Initio, 2. That On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit-1. Raipur Failed To Demonstrate That How The Order Passed By The Ao Is Erroneous Which Caused Prejudice To The Revenue. 3. That On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit-1. Raipur Has Stated In The Order That No Adverse Inference Is Drawn On The Issues Raised In Notice U/S 263, However, Set Aside The Proceedings Initiated U/S 263 Of The Act, Hence, The Same Is Contradictory & Incorrect. 4. The Appellant Craves To Add, Alter Or Delete Any Of The Grounds Of Appeal During The Course Of Appellate Proceedings,”

For Appellant: Shri Praveen Goyel, CAFor Respondent: Smt. Ila M. Parmar, CIT-DR
Section 143(3)Section 194Section 194JSection 263Section 40Section 438Section 80C

that the assessee being an individual and has filed his return of income on 10.10.2018. Subsequently, the case of the assessee was selected for complete scrutiny under the E- assessment scheme 2019 on the following issue: (i) Details of assets and liabilities. 3. The Ld. AO framed the assessment ... prejudicial to the interest of Revenue on the following grounds: “2. The case of the assessee was selected for complete scrutiny under E- assessment Scheme, 2019. The case was completed u/s 143(3) of the Income Tax Act. 1961 vide order 22.02.2021 and total income was assessed

J K Investo Trade (India), Mumbai vs. DCIT, CC-8(1), Mumbai

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

ITA 1836/MUM/2023[2018-19]Status: DisposedITAT Mumbai23 Aug 2023AY 2018-19

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm J K Investo Trade (India) Limited Dcit, Central Circle-8(1) (Successor To Raymond Consumer Care Mumbai Pvt. Ltd.) (Raymond Consumer Care Pvt. Ltd. Formerly Known As “J K Ansell Pvt. Vs. Ltd.”) 3, New Hind House, N M Marg, Ballard Estate, Mumbai-400 001

For Appellant: Shri Madhur Agarwal &For Respondent: 22.08.2023
Section 143(1)Section 143(3)Section 250Section 37(1)Section 80G

declaring total income at Rs.Nil and the same was processed u/s. 143(1) of the Act. The assessee’s case was selected for complete scrutiny and the assessment order dated 09.04.2021 was passed by the Assessing Officer ('A.O.' for short) u/s. 143(3) of the Act where the A.O. made

Trafogura Global Services Pvt Ltd, Mumbai vs. PCIT-6, Mumbai

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

ITA 1690/MUM/2023[2018-2019]Status: DisposedITAT Mumbai23 Aug 2023AY 2018-2019

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm Trafigura Global Services Pvt. Ltd. Pcit-6 501, 5Th Floor, Aaykara Bhawan Unit No. 1101, A-Wing, Plot No. C, 66G Block, One Bkc, Bandra Kurla Vs. M. G. Road, Mumbai-400 020 Complex, Mumbai – 400 051

For Appellant: Shri Madhur AgarwalFor Respondent: Shri Sanjay Deshmukh
Section 143(3)Section 263

assessee’s case was selected for limited scrutiny assessment on the issue of deduction from total income under Chapter VIA and not for complete scrutiny. The ld. AR further contended that the issue of allowability of expenditure was not before the A.O. during the assessment proceeding and that ... issued and duly served upon the assessee. It is evident from the records of the assessment order that neither was it a case of complete scrutiny nor was the issue pertaining to the expenses incurred by the assessee was before the A.O. during the assessment proceeding

Shri Osham Jain Temple Trust, Rajkot, at . Patanvav, Taluka Dhoraji, Dist. Rajkot vs. The CIT-(Exemptions), Ahmedabad

In the result, the matter is being set-aside to the file of the CIT(E) with the aforesaid directions

ITA 116/RJT/2021[2015-16]Status: DisposedITAT Rajkot23 Aug 2023AY 2015-16

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Darshak Thakkar, A.RFor Respondent: Shri Shramdeep Sinha, CIT DR
Section 11Section 11(1)(d)Section 143(3)Section 263

after claiming exemption under Section 11 of the Income Tax Act, 1961 (“Act”). The case of the assessee was selected for complete scrutiny with the reason to examine open “large corpus donation received by the assessee trust” and thereafter assessment was completed under Section