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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

Krishan Pal, New Delhi vs. ITO, Ward-34(1), Delhi

In the result, all the three captioned appeals of the

ITA 2250/DEL/2022[2017-18]Status: DisposedITAT Delhi09 Jan 2023AY 2017-18

Bench: Shri N.K. Billaiya & Shri Kul Bharat

For Appellant: Shri Sandeep Jain, CAFor Respondent: Ms. Maninder Kaur, Sr. DR
Section 143Section 143(1)Section 143(1)(a)

beyond the reasons 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. Meaning thereby, that exercise of power under sub-section (2) of section 143 of the Act leading

Savleen Kaur, New Delhi vs. ITO, Ward-54 (4), Delhi

In the result, all the three captioned appeals of the

ITA 2249/DEL/2022[2018-19]Status: DisposedITAT Delhi09 Jan 2023AY 2018-19

Bench: Shri N.K. Billaiya & Shri Kul Bharat

For Appellant: Shri Sandeep Jain, CAFor Respondent: Ms. Maninder Kaur, Sr. DR
Section 143Section 143(1)Section 143(1)(a)

beyond the reasons 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. Meaning thereby, that exercise of power under sub-section (2) of section 143 of the Act leading

B4S Solutions P.Ltd, New Delhi vs. ACIT, Circle-4(2), New Delhi

In the result, all the three captioned appeals of the

ITA 2197/DEL/2022[2019-20]Status: DisposedITAT Delhi09 Jan 2023AY 2019-20

Bench: Shri N.K. Billaiya & Shri Kul Bharat

For Appellant: Shri Sandeep Jain, CAFor Respondent: Ms. Maninder Kaur, Sr. DR
Section 143Section 143(1)Section 143(1)(a)

beyond the reasons 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. Meaning thereby, that exercise of power under sub-section (2) of section 143 of the Act leading

DCIT, Central Circle-19, New Delhi vs. Jaguar and Co. P.Ltd, Delhi

In the result, all the three captioned appeals of the assessee in ITA Nos

ITA 2115/DEL/2022[2019-20]Status: DisposedITAT Delhi09 Jan 2023AY 2019-20

Bench: Sh. N. K. Billaiya & Sh. Anubhav Sharmaassessment Year: 2019-20

Section 10ASection 139Section 143Section 143(1)Section 143(1)(a)Section 36

beyond the reasons 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. Meaning thereby, that exercise of power under sub- section (2) of section 143 of the Act leading

Naresh Kantilal Thacker, Gandhidham vs. Income Tax Officer, Ward-2, Gandhidham

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

ITA 28/RJT/2018[2014-15]Status: DisposedITAT Rajkot06 Jan 2023AY 2014-15

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 139Section 143(3)Section 2(14)(iii)

filed its Return of Income declaring income of Rs. 3,00,380/-. The return was selected for limited scrutiny assessment and then converted into complete scrutiny assessment vide PCIT letter dated 15.12.2016. 2.1. The assessee purchased a piece of land at Ajapar Village on 06.02.2014 for a consideration

Anuj Kumar, New Delhi vs. ACIT Circle-61, New Delhi

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

ITA 2998/DEL/2019[2015-16]Status: DisposedITAT Delhi04 Jan 2023AY 2015-16
For Appellant: Shri P.C. Yadav, AdvocateFor Respondent: Shri Kanav Bali, Sr. DR
Section 10Section 2Section 80C(3)

questionnaire and there is no mention in the assessment order regarding obtaining of approval of higher authority for converting the limited scrutiny case into complete scrutiny. Therefore, the addition made by the AO and confirmed by the CIT(A) may kindly be dismissed. 2 4. The ld. Sr. DR supported

Shri Dipten Ahindra Bhowmick, Gandhidham-Kutch vs. The ITO, Ward-1, Gandhidham-Kutch

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

ITA 134/RJT/2022[2016-17]Status: DisposedITAT Rajkot04 Jan 2023AY 2016-17

Bench: Shri Waseem Ahmed & Shri T. R. Senthil Kumar

For Appellant: Shri Gaurang Khakhar, A.RFor Respondent: Shri Shramdeep Sinha, CIT DR
Section 10Section 143(3)Section 154Section 250Section 264Section 264(1)Section 40A(3)

that there is a potential A.Y. 2016-17 6 escapement of income which exceeds Rs. 5 Lacs, he may convert the “Limited Scrutiny” into “Complete Scrutiny” with previous approval of PCIT in writing. The relevant portion of the instruction stands as under: “3. As far as the returns selected ... concerned, two type of cases have been selected for scrutiny in the current Financial Year- one is 'Limited Scrutiny' and other is 'Complete Scrutiny'. The assessees concerned have duly been intimated about their cases falling either in 'Limited Scrutiny' or 'Complete Scrutiny' through notices issued under section

DCIT Central Circle -2(3), Mumbai vs. M/S. Zarco Realities Pvt. Ltd, Mumbai

In the result, the In the result, the appeal of the Revenue is dismissed

ITA 1751/MUM/2022[2008-09]Status: DisposedITAT Mumbai30 Dec 2022AY 2008-09

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2008-09 Dcit Central Circle-2(3), M/S Zarco Realties Pvt. Ltd., Room No. 803, 8Th Floor, 1403, Godvari, Sir Prathishtha Bhavan, M.K. Vs. Pochkanwala Road, Worli, Road, Churchgate, Mumbai-400025. Mumbai-400020. Pan No. Aaacp 6265 H Appellant Respondent : Assessee By Mr. Vijay Mehta, Ar Revenue By : Mr. Satyapal Kumar, Dr : Date Of Hearing 20/12/2022 : Date Of Pronouncement 30/12/2022

For Respondent: Assessee by Mr. Vijay Mehta, AR
Section 143(1)Section 143(2)Section 147Section 148Section 68

Jaycee Industries Ltd. in F.Y. 2006 ycee Industries Ltd. in F.Y. 2006-07 relevant to A.Y. 2007 relevant to A.Y. 2007-08 and complete scrutiny u/s. 143(3) was 08 and complete scrutiny u/s. 143(3) was also carried out in respect of the re also carried out in respect

Unilever Industries Private Ltd, Mumbai vs. ACIT Range 1(3)(1), Mumbai

In the result, we do not find any merit in this appeal, the same fails and is hereby dismissed

ITA 1015/MUM/2021[2016-17]Status: DisposedITAT Mumbai29 Dec 2022AY 2016-17

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadaleunilever Industries Pvt Vs. Acit, Range – 1(3)(1) Ltd., Room No 504, 5 Floor, Unilever House, Bd Aayakar Bhavan, Sawant Marg, Chakala, M.K.Road, Andheri (E), Mumbai-400020 Mumbai -400099. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacu0791P Appellant .. Respondent Appellant By : Ms.Jasmin Amalsadvala & Mr.Hiten Chande.Ar Respondent By : Mr. Jayant Jhaveri.Dr Date Of Hearing 15.12.2022 Date Of Pronouncement 02.01.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Passed U/S 143(3) & U/Sec144C(13) R.W.S 143(3A) & 143(3B) Of The Income Tax Act, 1961 Passed In Pursuance To The Directions Of The Dispute Resolution Panel (Drp) Order U/S 144C(5) Of The Act Dated 26.02.2021.The Assessee Has Raised The Following Grounds Of Appeal. Unilever Industries Pvt Ltd, Mumbai. General: 1. On The Facts & In The Circumstances Of The Case & In Law, The Learned Ao/ Assistant Commissioner Of Income-Tax (Transfer Pricing) -4(2)(2) ("Tpo") Subsequent To The Directions Issued By The Hon'Ble Drp Has Erred In Assessing The Total Income At Rs. 152,67,16,425 As Against Returned Income Of Rs. 116,80,08,280 Computed By The Appellant. 2. Parti-Transfer Pricing Adjustments: Transfer Pricing ('Tp') Adjustment On Account Of Benchmarking & Allocation Of Royalty In Respect Of Provision Of Scientific & Technical Services ('Contract R&D')

For Appellant: Ms.Jasmin Amalsadvala &For Respondent: Mr. Jayant Jhaveri.DR
Section 143(3)Section 144C(5)

scrutiny and notice u/s 143(2) and 142(1) of the Act along with questionnaire was issued. Whereas the case was selected for complete scrutiny under e-assessment scheme 2019 on the fallowing issues as under: i. Whether double taxation relief (and income) has been shown correctly in the return

Mylan Pharmaceuticals Private Limited, Hyderabad vs. ITO Ward-16(3), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 122/HYD/2022[2016-17]Status: DisposedITAT Hyderabad26 Dec 2022AY 2016-17

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2016-17 Mylan Pharmaceuticals Vs. Ito,Ward-16(3) Private Limited I.T.Towers, Ac Guards Plot No.564/A/22, Masab Tank Road No.92 Hyderabad-500 004 Jubillee Hills, Hyderabad Telangana-500 096

For Appellant: Shri P.V.S.S.Prasad, CAFor Respondent: Shri Jeevan Lal Lavidiya,CIT-DR
Section 143(2)Section 143(3)Section 263Section 37(1)

group company. It filed its return of income on 30.11.2017 declaring total loss at Rs.56,78,76,827/-. The case was selected for complete scrutiny and statutory notices u/s. 143(2) and 142(1) were issued along with detailed questionnaire. The AR of the assessee in response to the same

Balaraj Guttamidi, Manikonda vs. Income Tax Officer, Ward-8(1), Hyderabad

In the result, the appeal of assessee is dismissed

ITA 262/HYD/2020[2017-18]Status: DisposedITAT Hyderabad21 Dec 2022AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2017-18 Balaraj Guttamidi, Vs. The Income Tax Officer, Ward – 8(1), R/O. Rangareddy. Hyderabad. Pan : Btlpg4930J. (Appellant) (Respondent) Assessee By: Shri T. Chaitanya Kumar. Revenue By: Shri Kumar Adithya. Date Of Hearing: 20.12.2022 Date Of Pronouncement: 21.12.2022

For Appellant: Shri T. Chaitanya KumarFor Respondent: Shri Kumar Adithya
Section 143(2)Section 143(3)Section 234ASection 54Section 54F

filed two additional grounds which read as under : “1. The Assessing officer erred in expanding the scope of assessment by converting limited scrutiny to complete scrutiny while completing the assessment u/s 143(3)on of the I.T. Act and the learned Commissioner Of Income Tax(Appeals) erred in confirming

Duckwoo Autoind Pvt. Ltd., Thiruvallur vs. PCIT-1, Chennai

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

ITA 232/CHNY/2021[2015-16]Status: DisposedITAT Chennai21 Dec 2022AY 2015-16

Bench: Shri Mahavir Singh, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.232/Chny/2021 िनधा"रण वष" /Assessment Year: 2015-16

For Respondent: Mr.S.Maruthu Pandian, CIT
Section 142(1)Section 143(2)Section 143(3)Section 263Section 271(1)(b)

concerned, two type of cases have been selected for scrutiny in the current Financial Year- one is ‘Limited Scrutiny’ and other is ‘Complete Scrutiny’. The assessees concerned have duly been intimated about their cases falling either in ‘Limited Scrutiny’ or :: 12 :: ‘Complete Scrutiny’ through notices issued under section ... monetary limit shall be Rs. ten lakhs) requiring substantial verification on any other issue(s), then, the case may be taken up for ‘Complete Scrutiny’ with the approval of the Pr. CIT/CIT concerned. However, such an approval shall be accorded by the Pr. CIT/CIT in writing after being satisfied about

Xchanging Solutions Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle-7(1)(1), Bangalore

In the result, the appeal is partly allowed

ITA 292/BANG/2022[2017-18]Status: DisposedITAT Bangalore21 Dec 2022AY 2017-18

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri K. Sankar Ganesh, Jt.CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 143(3)

No.292/Bang/2022 Page 2 of 42 of income for AY 2017-18 declaring an income of Rs.3,78,28,990. The case was selected for complete scrutiny and accordingly notice u/s. 143(2) was served on the assessee. The assessee later filed a revised return declaring a loss of Rs.3

Azad Hind Rice Mill, Burdwan vs. I.T.O., Ward-1(1), Burdwan

In the result, the appeal of assessee is allowed

ITA 559/KOL/2022[2017-2018]Status: DisposedITAT Kolkata13 Dec 2022AY 2017-2018
Section 143(2)Section 250Section 68

rice mill. Income of Rs.7,00,300/- declared in the return filed on 18-10-2017. Case was selected for scrutiny through CASS for complete Scrutiny for the reason of ‘cash deposit during demonetisation period’. Valid notices u/s. 143(2)/ 142(1) of the Act were served upon the assessee

M/S. Himali Vijay Builders & Developers, Mumbai vs. ACIT, Central Cir-2, Thane

In the result, both these appeals of the assessee are dismissed

ITA 1756/MUM/2022[2018-19]Status: DisposedITAT Mumbai12 Dec 2022AY 2018-19

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Kiran KapadiaFor Respondent: Shri Rakesh Ranjan
Section 132Section 143(3)Section 153ASection 250Section 80I

construction of the area for commercial and residential components called for by the A.O. Since, the impugned assessment year was an abated assessment year, complete scrutiny was made by the A.O. and, thereby passed the impugned assessment order u/s. 143(3) r.w.s. 153A. The A.O. concluded that the (A.Ys

M/S. Himali Vijay Builders & Developers, Mumbai vs. ACIT, Central Cir-2, Thane

In the result, both these appeals of the assessee are dismissed

ITA 1755/MUM/2022[2017-18]Status: DisposedITAT Mumbai12 Dec 2022AY 2017-18

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Kiran KapadiaFor Respondent: Shri Rakesh Ranjan
Section 132Section 143(3)Section 153ASection 250Section 80I

construction of the area for commercial and residential components called for by the A.O. Since, the impugned assessment year was an abated assessment year, complete scrutiny was made by the A.O. and, thereby passed the impugned assessment order u/s. 143(3) r.w.s. 153A. The A.O. concluded that the (A.Ys

Red Monster Mobile Pvt Ltd., Mumbai-400021 vs. Principal Commissioner of Income Tax-3, Mumbai-400020

In the result, appeal filed by the assessee is allowed

ITA 1248/MUM/2022[2015-16]Status: DisposedITAT Mumbai12 Dec 2022AY 2015-16

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blered Monster Mobile Private Limited V. Pr.Cit –3 213, Raheja Chambers Room No. 612, 6Th Floor Free Press Journal Marg Aayakar Bhavan, M.K. Road Nariman Point, Mumbai - 400021 Mumbai - 400020 Pan: Aagcr9963G (Appellant) (Respondent)

Section 115JSection 143(3)Section 263Section 56(2)(viib)

reason that the Assessing Officer did not seek the approval of the ld. Pr. CIT to convert the assessment from limited scrutiny to complete scrutiny. 8. In our view, if the Assessing Officer has not deemed it fit to apply to take approval from the ld. Pr. CIT/CIT ... conversion of a limited scrutiny case into a complete scrutiny, does it result in the assessment order passed u/s 143(3) of the Act, being erroneous insofar as it is prejudicial to the interest of the revenue. This is at best, an administrative lapse. When the Assessing Officer is prohibited

Subbunadar Chandra Sekar, Chennai vs. ITO, Cw-6(3), Chennai

The appeal stands allowed in terms of our above order

ITA 612/CHNY/2021[2016-17]Status: DisposedITAT Chennai06 Dec 2022AY 2016-17

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri T. Banusekar (C.A) – Ld. ARFor Respondent: Shri M. Rajan (CIT) – Ld. DR
Section 143(3)Section 263

pertinent to mention that unlike CASS 2015 and 2016 cycles, where consideration of any additional issue lead to the conversion of case to 'Complete Scrutiny' as laid down in Instruction No. 5/2016 dated 14.07.16, the pending 'Limited Scrutiny' cases of CASS 2017 and 2018 cycles would not be taken ... Complete Scrutiny' as the present directive is only to facilitate consideration of those issues wherein specific information of tax-evasion has been furnished by any law-enforcement/intelligence/regulatory authority or agency. Therefore, in such 'Limited Scrutiny' cases, Assessing Officer shall not expand the scope of enquiry/investigation beyond the issue

Invesco Asset Management (India) Private Limited, Mumbai vs. PCIT (Central), Mumbai-3, Mumbai

In the result, the appeal of the assessee is dismissed

ITA 700/MUM/2022[2017-18]Status: DisposedITAT Mumbai30 Nov 2022AY 2017-18

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.700/Mum/2022 (निर्धारण वर्ा / Assessment Years: 2017-18) Invesco Asset Management बिधम/ Pcit (Central), Mumbai- (India) Pvt. Ltd. 3 Vs. 21St Floor, 2101 “A” Wing, Room No. 612, 6Th Floor Marathon Futurex, Lower Aayakar Bhavan, Parel, Mumbai-400013. Maharshi Karve Road, Mumbai-400020. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaccg3908J (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Niraj Seth Revenue By: Shri K. C. Salvamani (Dr) सुनवाई की तारीख / Date Of Hearing: 02/11/2022 घोषणा की तारीख /Date Of Pronouncement: 30/11/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Action Of The Ld. Principal Commissioner Of Income Tax-3, Mumbai Dated 07.03.2022 For Assessment Year 2017-18 Passed Under Section 263 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

For Appellant: Shri Niraj SethFor Respondent: Shri K. C. Salvamani (DR)
Section 143(3)Section 263

Assessing Officer of allowability of ESOP expenses of Rs.11,30,93,503 by holding that the appellant’s case was selected for ‘complete scrutiny” and that the Assessing Officer ought to have verified the issue of allowability of ESOP expenses inspite of the fact that the appellant’s case ... assessment records it came to his notice that the assessee’s case was not selected for “limited scrutiny” but it was a case of complete scrutiny, and the AO has wrongly mentioned that the assessee’s case was selected for “limited scrutiny assessment”. According to the Ld. PCIT, the fact

Dy CIT - 26(1), Mumbai vs. M/S. Pratibha China State Joint Venture Universal Majextic, Mumbai

In the result appeal of the Revenue is dismissed

ITA 468/MUM/2021[2014-15]Status: DisposedITAT Mumbai29 Nov 2022AY 2014-15

Bench: Shri Aby T Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.468 /Mum/2021 (निर्धारण वर्ा / Assessment Year: 2014-15) बिधम/ Dy. Commissioner Of Income Tax-26(1) M/S Pratibha China State Room No 623, 6Th Floor, Kautilya Bhavan, Joint Venture Vs. Universal Majestic, 14Th Bandra Kurla Complex Bandra East, Mumbai-400051 Floor, Off Eastern Expressway, Ghatkopar Mankhud Link Road, Govandi, Mumbai-400043 स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aabap0740 (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: None Revenue By: Mr. Hiren Bhatt, Sr Ar सुनवाई की तारीख / Date Of Hearing: 31/10/2022 घोषणा की तारीख /Date Of Pronouncement: 29/11/2022 आदेश / O R D E R Per Aby T. Varkey, Jm:

For Appellant: NoneFor Respondent: Mr. Hiren Bhatt, Sr AR
Section 143(2)Section 145

assessee filed return of income for A.Y. 2014-15 on 26.11.2014 declaring total income of Rs. 33,46,947/-. The case was selected for complete scrutiny under CASS and after services of statutory notices u/s.143(2) & 142(1) of the Income Tax Act 1961 (herein after the Act) the assessment ... year under consideration i.e. AY 2014-15, the assessee filed ROI declaring income of Rs.33,44,947/-. Assessee’s ROI was picked up for complete scrutiny and as per the application of assessee u/s 144A of the Act, the assessment was carried out under the guidance and directions of JCIT