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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

Srirangarao Nadipallly, Karimnagar vs. ACIT., Circle-1, Karimnagar

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

ITA 844/HYD/2025[2016-17]Status: DisposedITAT Hyderabad09 Jan 2026AY 2016-17

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.844/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Shri Srirangarao Nadipally Vs. Assistant Commissioner Karimnagar Of Income Tax Pan:Acbpn3816E Circle-1, Karimnagar (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Adv. Kvssn Kumar राज" व "ारा/Revenue By: Sankar Pandi P - Sr. Dr सुनवाई की तारीख/Date Of Hearing: 05/01/2026 घोषणा की तारीख/Pronouncement: 09/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Srirangarao Nadipally (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 24.03.2025 For The A.Y 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Adv. KVSSN KumarFor Respondent: Sankar Pandi P - Sr. DR
Section 143(2)Section 143(3)

effect: 9. On perusal of above, we find that although the case was initially selected for limited scrutiny, the same was subsequently converted into complete scrutiny. Despite such complete scrutiny, no adverse observation has been recorded by the Ld. AO with respect to the closing cash balance of Rs.91 ... assessee had disclosed agricultural income of Rs.9,00,000/- in the immediately preceding assessment year as well, which was the subject matter of complete scrutiny assessment and no adverse observation was recorded by the Ld. AO in that year. He therefore contended that once the agricultural income was accepted

Saurashtra Cement Limited, Porbandar vs. The Principal Commissioner of Income Tax, Jamnagar

In the result, appeal filed by the assessee is allowed

ITA 307/RJT/2024[2018-19]Status: DisposedITAT Rajkot08 Jan 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.307/Rjt/2024 िनधा"रणवष"/ Assessment Year: 2018-19 Saurashtra Cement Ltd. Principal Commissioner Of Near Railway Station, बनाम Income Tax, Jamnagar, Saurashtra Cement Factory, Jamnagar Vs. P.O. Ranavav, Adityana Road, Porbandar, Gujarat-360560 Pan : Aahfs5211J (अपीलाथ"/Assessee) : (""थ"/Respondent) िनधा"रती की ओर से/Assessee By : Shri Vimal Desai, Ld.Ar राज" की ओर से/Revenue By : Shri Sanja Punglia, Ld. Cit-Dr सुनवाई की तारीख/Date Of Hearing : 16/10/2025 घोषणा की तारीख/Date Of Pronouncement : 08/01/2026 Order

For Appellant: Shri Vimal Desai, ld.ARFor Respondent: Shri Sanja Punglia, Ld. CIT-DR
Section 143(3)Section 14ASection 263Section 36(1)(iii)

Rs.33,24,12,992/-, under normal provisions and Book Profit of Rs. 46,83,48,940/-. The case of the assessee was selected for Complete Scrutiny assessment under the E-assessment Scheme, 2019. Accordingly, the assessment order was passed u/s 143(3) r.w.s. 144C(3) of the Income ... being repeated for the sake of brevity. Learned DR for the revenue also submitted that assessee`s case was selected for complete scrutiny and not for limited scrutiny, therefore, there is no findings in the assessment order that assessing officer has examined these issues which were raised by the learned

Tooltech Global Engineering Pvt. Ltd., Pune vs. Income Tax Officer, Ward 7(5), Pune

In the result, appeal of the Assessee is dismissed

ITA 2212/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2212/Pun/2025 निर्धारण वषा / Assessment Year : 2017-18 Tooltech Global Engineering V The Income Tax Pvt. Ltd., S Officer, 401, Beta 1, Giga Space, Ward-7(5), Pune. Viman Nagar,Pune – 411014. Pan: Aabct0205A Appellant/ Assessee Respondent /Revenue Assessee By Shri Samir Shah Revenue By Shri Ambarnath Khule-Jcit(Through Virtual Hearing) Date Of Hearing 27/11/2025 Date Of Pronouncement 08/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(Appeal)-3, Chennai Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2017-18Dated 28.07.2025 Emanating From The Assessment Order Passed Under Section 143(3) Of The Act, Dated 26.12.2019. The Assessee Has Raised The Following Grounds Of Appeal : “1. On The Basis Of Facts Of The Case & In Law The Ld. Commissioner Of Income Tax (Appeals) Has Erred In Confirming The Action Of The

Section 143(3)Section 250Section 37

perused the records. In this case, Assessee had filed Return of Income for A.Y.2017-18 electronically on 29.11.2017. Assessee’s case was selected for 2 complete scrutiny. Accordingly, the Assessing Officer has issued ITA No.2212/PUN/2025 [A] various notices to the Assessee. The Assessment Order was passed on 26.12.2019 under section

Late Madan Lal Gupta Through Legal Heir Abhishek Gupta, Barabanki vs. ITO Ward 5(4), Barabanki-1, Barabanki

In the result, the appeal of the assessee stands allowed

ITA 437/LKW/2025[2017-18]Status: DisposedITAT Lucknow07 Jan 2026AY 2017-18

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Late Madan Lal Gupta V. Ito Through Legal Heir Ward 5(4) Abhishek Gupta Barabanki - 1 367, Qanoon Goyan Nawabganj, Barabanki U.P) Tan/Pan:Acepg5468Q (Applicant) (Respondent) Applicant By: Shri Gaurav Gupta, C.A. Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 25.05.2025, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2017-18. 2.0 The Brief Facts Of The Case Are That The Assessee Was A Retired Assistant Engineer In The U.P. Power Corporation, Drawing Pension. The Assessee E-Filed His Return Of Income For The Year Under Consideration On 27.07.2017 Declaring A Total Income Of Rs.4,78,310/- After Claiming A Deduction Under Chapter Vi-A, Amounting To Rs.1,50,000/-. The Case Of The Assessee Was Selected For Limited Scrutiny Under The Computer Aided Scrutiny Selection (Cass) For The Reason Of ‘Cash Deposit During The Demonetization Period’. Accordingly, A Notice Under Section 143(2) Of The Income Tax Act, 1961 (Hereinafter Called

For Respondent: Shri R.R.N. Shukla, D.R
Section 115BSection 142(1)Section 143(2)Section 143(3)Section 69A

codified and conditions along with the prior approval of Pr. CIT/CIT in writing after being satisfied about the merits of the issue(s) necessitating 'Complete Scrutiny' in that particular case. 1.3. The impugned order contradicts the CBDT instruction no.3/2017 dated 21st February 2017 whereby cash deposit to the tune ... included cash deposits pertaining to entire year under consideration. It was further submitted that the scope of limited scrutiny had been enlarged to complete scrutiny without obtaining the necessary approval as mandated by the CBDT, vide Instruction No.20/2015 dated 29.12.2015. It was submitted that since there was no approval

Surabi Educational and Charitable Trust, Dindigul vs. ACIT, Exemptions, Coimbatore

In the result, all the appeals of the assessee for AY 2018-19 and AY

ITA 2759/CHNY/2025[2018-19]Status: DisposedITAT Chennai07 Jan 2026AY 2018-19

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2759, 2760, 2761, 2762, 2763, 2764 & 2765/Chny/2025 निर्धारण वर्ष / Assessment Years: 2018-19 & 2020-21 Surabi Educational & Charitable Trust, S7/2 Prnp Complex, Kumaran Thiru Nagar, Silavathur Road, Dindigul – 624 005. Pan: Aafts 0804D (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Respondent By सुनवाई की तारीख/Date Of Hearing घोषण की तारीख / Date Of Pronouncement Per Padmavathy.S, A.M: The Asst. Commissioner Of Income Vs. Tax (Exemptions), Coimbatore. (प्रत्यर्थी/Respondent) Mr. Richard Joseph, Advocate Ms. Latchana, Jcit 16.12.2025 07.01.2026 आदेश / Order These Appeals By The Assessee Are Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi, (In Short "Cit(A)") Passed U/S. 250 Of The Income Tax Act, 1961 (In Short "The Act") For Assessment Years (Ay) 2018-19 & 2020-21. The Order Of The Cit(A) Is Emanating From The Order Of The A.O Passed U/S. 143(3) & The Penalty Orders U/S. 270A, 271Aac(1), 272A(1)(D) & 272A(1)(C) Of The Act. For The Purpose Of Adjudication, We Will First Consider The Appeal Filed For A.Y 2018-19.

Section 143(3)Section 250Section 270A

Penalty Appeal: 6. For AY 2020-21 the assessee filed the return of income on 12.01.2021 declaring Nil income. The case was selected for complete scrutiny and the statutory notices were duly served on the assessee. The A.O. called for various details during the course of assessment. Since the assessee