“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

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

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

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

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

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

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

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

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

Deepak Kumar Yadav, Rewari vs. ITO, Rewari

In the result, appeal of the assessee is allowed

ITA 8579/DEL/2025[2020-21]Status: DisposedITAT Delhi21 Jan 2026AY 2020-21

Bench: Shri Satbeer Singh Godaraassessment Year: 2020-21 Sh. Deepak Kumar Yadav, Vs. Income Tax Officer, Village-Kapriwas, Ward-2, Rewari, Dharuhera, Haryana Rewari-123401 Pan: Abrpy2885R (Appellant) (Respondent) Assessee By None Department By Sh. Manoj Kumar, Sr. Dr

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

declaring income of Rs. 6,35,470/-. His return was processed under section 143(1)(a) on 28.06.2019. His case was selected for complete scrutiny assessment under the e-assessment Scheme, 2019 on two issues, namely refund claim and winning from 2 | P a g e Lottery/crossword puzzle/horse races

Assertive Infrastructure Pvt. Ltd., Delhi vs. ITO Ward 3(3), New Delhi

In the result, appeal of the assessee is partly allowed

ITA 4200/DEL/2025[2014-15]Status: DisposedITAT Delhi21 Jan 2026AY 2014-15

Bench: Shri Mahavir Singh & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 194Section 250Section 40

sector 150, Noida. The assessee company e-filed its return of income, declaring income at NIL on 30.11.2014. The case was selected for complete scrutiny under CASS by way of issue of notice u/s 143(2) of the Act on 31.08.2015. Thereafter, statutory notices u/s 142(1) alongwith questionnaire were

DCIT, Circle-7(1), Delhi vs. Fis Global Business Solutions India Pvt. Ltd., Delhi

In the result, appeal filed by the Revenue is dismissed

ITA 2405/DEL/2025[2016-17]Status: DisposedITAT Delhi21 Jan 2026AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Ms. Reema Grewal, CAFor Respondent: Shri Ajay Kumar Arora, Sr.DR

Section 142(1)Section 143(2)Section 92B(2)Section 92C

company E-filed its return of income on 30.11.2016 declaring total Income of Rs.1,49,38,61,840/-. Subsequently, the case was selected for Complete Scrutiny through CASS with the reasons "Large any other amount allowable as deduction" claimed in schedule BP of return; Tax Credit claimed

DCIT, Delhi vs. Ramakrishna Electro Components Pvt. Ltd., Delhi

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

ITA 2744/DEL/2024[2017-18]Status: DisposedITAT Delhi21 Jan 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla[Assessment Year:2017-18] Dcit, Ramakrishna Electro Components Room No.221, 2Nd Floor, C.R Pvt. Ltd., B-79, Basement, Building, I.P. Estate, Vs Ground, 1St & 3Rd Floor, New Delhi-110002 Wazirpur Industrial Area, Wazir Pur Iii, North West Delhi, Delhi-110052 Pan Aabcr7886H Appellant Respondent Cross Objection No.81/Del/2024 [In Ita No.2744/Del/2024] [Assessment Year:2017-18] Ramakrishna Electro Dcit, Room No.221, 2Nd Floor, C.R Components Pvt. Ltd. B-79, Basement, Ground, Vs Building, I.P. Estate, 1St & 3Rd Floor, Wazirpur New Delhi-110002 Industrial Area, Wazir Pur Iii, North West Delhi, Delhi-110052 Pan Aalca5543N Appellant Respondent Revenue By Ms. Pooja Swaroop, Cit(Dr) Assessee By Shri Satyajeet Goel, Advocate & Shri Rajat Garg, Ca Date Of Hearing 14.01.2026 Date Of Pronouncement 21.01.2026 Co No.81/Del/2024 Order Per Amitabh Shukla, Am

Section 115BSection 142(1)Section 143(1)Section 143(2)Section 143(3)Section 68

income of Rs. 1,61,99,240/-. The return was processed u/s 143(1) of the Act. The case was selected under CASS for complete scrutiny. Statutory notice u/s 143(2) of the Act dated 14.8.2018 was issue and served upon the assessee. Thereafter notices u/s 142(1) alongwith questionnaire

Patliputra Distributors Private Limited, Patna vs. Dc/Ac, Circle-2, Patna

In the result, the appeal filed by assessee as well as the appeal of revenue stands allowed for statistical purposes

ITA 319/PAT/2025[2017-18]Status: DisposedITAT Patna20 Jan 2026AY 2017-18

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

Section 115BSection 143(2)Section 143(3)Section 250Section 271ASection 69A

business of wholesale trading, filed its return of income on 06.11.2017 declaring income at Rs. 1,77,07,480/-. The case was selected for complete scrutiny. Accordingly, notice u/s 143(2) of the Act dated 25.09.2018 was duly served to the assessee and subsequently, other statutory notices were issued ... Considering the rival submissions and perusing the material available on record and orders of authorities below. We noted that the case was selected or complete scrutiny and on the basis of cash deposits during the demonetization period for Rs. 2,10,38,900/- in its 5 Patliputra Distributors Private Limited

Thangamayil Jewellery Ltd., Madurai vs. DCIT, Corproate Circle, Madurai

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 2659/CHNY/2025[2018-19]Status: DisposedITAT Chennai20 Jan 2026AY 2018-19

Bench: Shri Aby T Varkey & Shri S.R.Raghunatha

For Appellant: Mr.Shiva Srinivas, CITFor Respondent: 17.12.2025

Section 115JSection 143(3)

admitting a total income of Rs.14,28,12,990/- and book profit u/s.115JB of Rs.34,40,85,658/-. 3. The case was selected for complete scrutiny assessment under CASS for both the A.Y.2017-18 and 2018-19 and the Assessing Officer issued statutory notices and details called for. In response

Thangamayil Jewellery Ltd., Madurai vs. DCIT, Corporate Circle, Madurai

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 2658/CHNY/2025[2017-18]Status: DisposedITAT Chennai20 Jan 2026AY 2017-18

Bench: Shri Aby T Varkey & Shri S.R.Raghunatha

For Appellant: Mr.Shiva Srinivas, CITFor Respondent: 17.12.2025

Section 115JSection 143(3)

Krishan Kumar Yadav, Rewari vs. ITO, Ward-2, Rewari

In the result, appeal of the assessee is allowed

ITA 8417/DEL/2025[2020-21]Status: DisposedITAT Delhi20 Jan 2026AY 2020-21

Bench: Sh. Satbeer Singh Godaraita No. 8417/Del/2025 : Asstt. Year: 2020-21 Krishan Kumar Yadav, Vs Income Tax Officer, Bank Of Baroda, Circular Road, Ward-2, Rewari, Haryana-123401 Rewari, Haryana-123401 (Appellant) (Respondent) Pan No. Aabpy1644F Assessee By: Sh. I. P. Bansal, Adv. & Sh. Vivek Bansal, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 20.01.2026 Date Of Pronouncement: 20.01.2026 Order This Assessee’S Appeal For Assessment Year 2020-21 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1081822094(1) Dated 16.10.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. I. P. Bansal, Adv. &For Respondent: Sh. Manoj Kumar, Sr. DR

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

Assistant Commissioner of Income Tax, Circle 1, Bhavnagar vs. Rudra Global Infra Products Limited, Bhavnagar

In the result, the appeal of the Revenue as well as the Cross-Objection filed by the assessee, both are dismissed

ITA 1163/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad19 Jan 2026AY 2022-23

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

Section 133(6)Section 143(1)Section 143(2)Section 250

parameters as noted in para 03 of assessment order and thus acted in violation of CBDT instruction F. No. 225/66/2023/ITA-II Dated 24.05.2023 that mandated complete scrutiny only in respect of compulsory selection and the assessee did not meet that criterion as per Para 3 because selection of case was done

Income Tax Officer, Ward-41(3)(1), Mumbai vs. Dahyalal Gagjibhai Jiwani, Surat

ITA 7004/MUM/2025[2022-23]Status: DisposedITAT Mumbai19 Jan 2026AY 2022-23

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rahul SardaFor Respondent: Shri Annavaran Kosuri

Section 143(3)Section 144BSection 68

declaring total income of Rs. 10,10,580. The case was selected for Complete Scrutiny assessment through CASS as there was Substantial increase in the capital during the financial year as compared to previous year. The AO found that during FY 2021- 22, the appellant’s capital increased

Sheth Realtors, Mumbai vs. ACIT-CC-7(1), Mumbai

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

ITA 5947/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Arun Khodpiashri Sandeep Singh Karhailsheth Realtors Vasant Oasis, Site Office, Upper Basement, Cts No.345A 1 To 3, 345A 5 To 6, Makwana Road, Marol, Andheri (East), ............... Appellant Mumbai – 400059 Pan: Aavfa3975F

For Appellant: Dr. K ShivramFor Respondent: Shri Vivek Perampurna, CIT-DR

Section 133(6)Section 139(1)Section 2(24)(x)Section 250

under 4 consideration, the assessee filed its return of income on 08/10/2018, declaring Nil income. The return filed by the assessee was selected for complete scrutiny under CASS, and statutory notices under section 143(2) and section 142(1) of the Act were issued and served on the assessee. During

Vimla Devi Thakran, Gurgaon vs. Income Tax Officer, New Delhi

In the result, appeal of the assessee is allowed

ITA 8305/DEL/2025[2017-18]Status: DisposedITAT Delhi19 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Vimla Devi Thakran, Vs. Income Tax Officer, I Tower, Ea-8, 6Th Floor, Tata Ward -43(2), Primanti, South City-Ii, New Delhi Sector-72, Gurgaon Pan: Agfpt4774R (Appellant) (Respondent) Assessee By Sh. S.K. Wadhwa, Ca Department By Sh. Manoj Kumar, Sr. Dr

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(viii)Section 57

Mahender, Huda Colony, Hansi vs. Income Tax Ward-1, Hisar, Aayakar Bhawan

In the result, appeal of the assessee is allowed

ITA 8139/DEL/2025[2020-21]Status: DisposedITAT Delhi19 Jan 2026AY 2020-21

Bench: SHRI SATBEER SINGH GODARA (Judicial Member)

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

Centre for General Education Society, Ghaziabad vs. CIT(Exemption), Delhi

In the result, the appeal of the assessee is allowed

ITA 2423/DEL/2025[2020-21]Status: DisposedITAT Delhi19 Jan 2026AY 2020-21

Bench: Shri Mahavir Singh & Smt. Renu Jauhricentre For General Vs. Cit Exemption Education Society, Lucknow A-16, Site-3, Merrut Road Upside Indl. Area, Ghaziabad (Pan: Aaatc8262G) (Appellant) (Respondent) Assessee By : S/Shri Akhilesh Kumar, Adv. & Govind Agarwal, Adv. Revenue By : Shri Jitender Singh, Cit(Dr)

For Appellant: S/Shri Akhilesh Kumar, Adv. & Govind Agarwal, AdvFor Respondent: Shri Jitender Singh, CIT(DR)

Section 10Section 12ASection 142(1)Section 143(2)Section 143(3)Section 263Section 80G

sources. The assessee filed its return of income for the relevant assessment year 2020-21 on 12.12.2020 and assessee’s case was selected for complete scrutiny assessment with the following reasons:- i) Expenditure for Charitable or Religious Purposes. ii) Accumulation of Income by Trust. 3.1 Accordingly, notice

Kalpana Narware, Betul vs. Income Tax Officer, Betul

Appeal is allowed for statistical purpose

ITA 202/IND/2025[2017-18]Status: DisposedITAT Indore16 Jan 2026AY 2017-18

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

Section 144Section 253

## आयकर अपीलीय अिधकरण**,** इंदौर Ɋायपीठ**,** इंदौर **IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE** ### **BEFORE SHRI B.M. BIYANI, ACCOUNTANT

Deputy Commissioner of Income Tax Circle 2 1 1 Ahmedabad, Ahmedabad vs. Khyati Chemicals Private Limited, Ahmedabad

In the result, the appeal filed by the Revenue is hereby allowed

ITA 1856/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2018-19

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(3)Section 198Section 37(1)Section 40ASection 40A(2)(b)

Rs.17,84,76,810/- and lateron filed a revised return on 08-02-2019 declaring the same income. The return was taken for complete scrutiny assessment and issued various notices calling for details and made the following disallowances: (i) Disallowance

M.S. Builders, Moradabad vs. ITO Ward-1(1), Moradabad

ITA 616/DEL/2025[2018-19]Status: DisposedITAT Delhi16 Jan 2026AY 2018-19

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 143(2)Section 143(3)Section 145Section 250

lands etc. and filed its return of income on 30.10.2018, declaring total income of INR 5,92,243/-. The case was selected for complete scrutiny under CASS for the reason “income from Real Estate Business”. A notice u/s 143(2) was issued on 22.09.2019 followed by notices us/142(1) alongwith

Satish Kumar Mailik, New Delhi vs. ITO Ward 52(3), New Delhi

In the result, appeal of the assessee is partly allowed

ITA 4307/DEL/2025[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalsatish Kumar Malik, Income Tax Officer, 2/31, Ansari Road, Darya Ganj, Ward-52(3), New Delhi-110002. Vs. Delhi. Pan-Adrpm7097D (Appellant) (Respondent) Assessee By Shri R.M. Mehta, Ca & Shri J.P. Chawla, Ca Department By Shri Jitender Singh, Cit-Dr Date Of Hearing 24/11/2025 Date Of Pronouncement 16/01/2026 O R D E R Per Manish Agarwal, Am: The Present Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dated 28.05.2025 In Appeal No. Cit(A), Delhi-18/10299/2019-20 Arising Out Of The Order Passed U/S 143(3) Of The Income Tax Act, 1961 (‘The Act’ In Short) Dated 30.12.2019 For Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is An Individual & Engaged In The Business Of Trading Of Goods. The Return Of Income For The Year Under Appeal Was Filed On 02.11.2017 Declaring Total Income Of Rs.26,19,530/- & The Case Of The Assessee Was Selected Under Complete Scrutiny Under Cass For The Reason “Abnormal Increase In Cash Deposit During The Demonetization”. Thereafter, Notice U/S 143(2) Satish Kumar Malik Vs. Ito Followed By Notices U/S 142(1) Were Issued From Time To Time, In Response To Which Assessee Filed Written Submissions. After Considering The Submissions Filed By The Assessee The Ao Was Of The Opinion That Assessee Had Deposited Cash Of Rs.44,44,750/- In Bank During Demonetization Period In Sbn Source Of Which Was Not Explained And, Therefore, Made The Addition Of The Said Cash As Unexplained Credits U/S 68 Of The Act & Further Invoked The Provisions Of Section 115Bbe Of The Act & Charge Tax At The Higher Rate.

Section 115BSection 142(1)Section 143(2)Section 143(3)Section 145(3)Section 68

year under appeal was filed on 02.11.2017 declaring total income of Rs.26,19,530/- and the case of the assessee was selected under complete scrutiny under CASS for the reason “abnormal increase in cash deposit during the demonetization”. Thereafter, notice u/s 143(2) Satish Kumar Malik vs. ITO followed

Atma Ram Builders Private Limited, New Delhi vs. Income Tax Officer, Central Circle 5, New Delhi

In the result, appeal of the Assessee is allowed in above terms

ITA 3593/DEL/2025[A.Y. 2020-21]Status: DisposedITAT Delhi16 Jan 2026

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

Section 143(3)Section 263Section 269TSection 270ASection 271ESection 69ASection 80G

13th February, 2021 admitting an income of Rs.13,53,93,940/-. The case of the assessee was selected for scrutiny vide CASS under complete scrutiny category for the following reasons as enumerated in para 3 as extracted below: - “3. Complete description of issues (issue wise) The assessee's case ... Aggregate other Income: Rs. 7,13,90,455/-etc., 4. The assessee furnished submissions on various dates to the show cause notice during complete scrutiny assessment. With respect to the cash deposits, it was stated that the assessee has made cash deposits of Rs. 3,97,06,452/- in HDFC

Income Tax Officer, Exemption vs. Dogra Educational Society, Ground Floor

The appeal of the revenue is dismissed

ITA 4569/DEL/2024[2018-19]Status: DisposedITAT Delhi16 Jan 2026AY 2018-19

Bench: Shri Anubhav Sharma & Shri Manish Agarwalincome Tax Officer, Vs. Dogra Educational Society Exemption, Ward-1(3), Ground Floor, 416 Bhera Room No.2419, 24Th Floor, Enclave, Pachim Vihar E-2 Floor, Civic Centre Delhi – 110058 Delhi – 110001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaatd4135D Appellant .. Respondent

For Appellant: NoneFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr

Section 11Section 119(2)(b)Section 12ASection 12A(1)Section 139Section 139(4)Section 143(3)

trust filled its return of income u/s 139(4) for the A.Y. 2018-19 on 30.03.2019 with NIL income. The case was selected for Complete Scrutiny assessment under the e-assessment Scheme, 2019 on the issue- "Expenditure for Charitable or Religious Purposes". The assessment in the case was completed assessing