“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

Gopal Aggarwal, Faridabad vs. ITO(OSD)-Faridabad, Faridabad

In the result, appeal of the assessee is allowed

ITA 1678/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Dec 2025AY 2017-18

For Appellant: Manish Kumar, AdvocateFor Respondent: Shri Manish Gupta, Sr. DR

present case was selected for limited scrutiny. However, the Ld. AO proceeded to pass the assessment order as if it were a case of complete scrutiny, without obtaining the mandatory approval of the competent authority for conversion of the limited scrutiny into complete scrutiny. The Ld.AR thus submitted that

Saurav Malik, Dehradun vs. Income Tax Officer, Dehradun

In the result, appeal of the assessee is allowed

ITA 49/DDN/2025[2017-18]Status: DisposedITAT Dehradun24 Dec 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2017-18] Saurav Malik Vs Ito 100/2, Bell Road Clement Town 15A, Subhash Road, Near Hilton School, Dehradun Uttarakhand Uttarakhand-248002 Pan-Bdypm6527J Appellant Respondent Assessee By Shri Rajiv Sahini, Ca Revenue By Shri A.S. Rana, Sr. Dr Date Of Hearing 09.10.2025 Date Of Pronouncement 24.12.2025

Section 127Section 142(1)Section 143(2)Section 143(3)Section 250Section 69A

that assessee e-filed his return of income on 29.10.2017, declaring total income of INR 7,59,830/-. The case was selected for complete scrutiny under CASS with the reason that “Abnormal increase in cash deposits during demonetization period as compared to pre-demonetization period.” Accordingly, notice

Shalini Srivastava, Haldwani vs. Ward 2(1)(1) Haldwani/, Haldwani

In the result, appeal of the assessee is partly allowed

ITA 121/DDN/2025[2019-20]Status: DisposedITAT Dehradun24 Dec 2025AY 2019-20

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year :2019-20] Shalini Srivastava Vs Ward-2(1)(1) Sheeshmahal, Opp. Haldwani Filter House, Uttarakhand Kathgodam, Haldwani, Uttarakhand-263139 Pan-Apyps8567D Appellant Respondent Assessee By Shri Prashant Kackar, Ca Revenue By Shri Amar Pal Singh, Sr.Dr Date Of Hearing 09.10.2025 Date Of Pronouncement 24.12.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 08.07.2025 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2018-19/10096852 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of The Assessment Order Dated 28.09.2021 Passed U/S 144 R.W.S. 144B Of The Act Pertaining To Assessment Year 2019-20. 2. Brief Facts Of The Case Are That Assessee Filed Her Return Of Income, Declaring Income From House Property Of Inr 51,754/- & Income Under The Head “Other Sources” Of Inr 17,56,736/-. The Total Income Of Inr 18,08,490/- Was Claimed As Set Off Against The Current Year Losses From Business & Profession Of Inr 31,04,998/- & Thus Total Income At Inr Nil Was Declared After Claiming Of Deduction Under Chapter Via Of Inr 1,56,918/-. The Return Of Income Was Selected For Complete Scrutiny. Notices U/S 143(2) Followed By Notices U/S 142(1) Were Issued From Time To Time Which Were Not Complied With. In Absence Of Any Reply By The Assessee, Order Was Passed U/S 144 As Per Information Available & Total Income Of The Assessee Was Assessed At Inr 13,32,38,065/- By Making Various Addition.

Section 142(1)Section 143(2)Section 144Section 250Section 68

declared after claiming of deduction under Chapter VIA of INR 1,56,918/-. The return of income was selected for complete scrutiny. Notices u/s 143(2) followed by notices u/s 142(1) were issued from time to time which were not complied with. In absence of any reply

M/S Thdc India Limited, Rishikesh vs. PCIT, Dehradun

Appeal of the assessee is partly allowed

ITA 69/DDN/2024[2020-21]Status: DisposedITAT Dehradun24 Dec 2025AY 2020-21

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

Section 142(1)Section 143(2)Section 143(3)Section 234ASection 250Section 251(1)(a)Section 270ASection 80

India. The return of income was filed on 05.01.2021, declaring total income of INR 869,04,14,340/-. The case was selected for complete scrutiny under CASS and notice u/s 143(2) of the Act was issued on 29.06.2021. Thereafter notices u/s 142(1) alongwith questionnaire were issued from time

Amish Jayeshbhai Dadawala, Vadodara vs. The ITO, Ward-1(2)(1) Previously Ward-1(1)(2), Vadodara

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

ITA 1528/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad24 Dec 2025AY 2017-18

Bench: Shri Suchitra Kamble

For Appellant: Shri Alok Shah, A.RFor Respondent: Shri Suresh Chand Meena, Sr. D.R

Section 142(1)Section 143(2)Section 143(3)Section 24BSection 250Section 69A

income for assessment year 2017-18 on 31-03-2018 declaring total income of Rs.4,61,790/-. The assessee's case was selected for complete scrutiny to examine specific issue i.e. larger value cash deposits during demonetization period as compared returned income and high value receipt of cash shown from

Sabarmati Gas Limited, Gandhinagar vs. Pr.CIT, Ahmedabad-3, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1219/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad24 Dec 2025AY 2020-21

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year 2020-21

For Appellant: Shri S.N. Soparkar, Sr. A.RFor Respondent: Shri Ashesh Rajesh Rewar, CIT-D.R

Section 263Section 32(1)Section 32(1)(iia)Section 80G

assessee company filed original return of income declaring income of Rs. 1,13,28,39,640/-. The case of the assessee was selected for complete scrutiny. The statutory notices issued to the assessee and in response to the said notices were received along with details by the Assessing Officer

ACIT., Circle-5(1), Hyderabad vs. Madineni Sitaramaiah, Hyderabad

In the result, the appeal filed by the Revenue is allowed, and the cross- objection filed by the assessee is dismissed

ITA 598/HYD/2025[2018-19]Status: DisposedITAT Hyderabad24 Dec 2025AY 2018-19

Bench: Us:

Section 143(3)Section 2(22)(e)

issue not covered under limited scrutiny reasons cannot be sustained unless there is prior approval from CIT for conversion of limited scrutiny into complete scrutiny. 5 The learned CIT(A), NFAC thus erred in concluding that the Assessing Officer did not travel beyond the examination of the reasons for limited ... that since the case was selected for “limited scrutiny”, the AO could not have invoked section 2(22)(e) without converting the case into complete scrutiny. Secondly, the assessee challenged the addition on merits by reiterating that the transactions were current account transactions and that

ACIT Circle-4(3)(1), Mumbai vs. Khadamat Integrated Solutions Pvt Ltd, Mumbai

ITA 3766/MUM/2024[2016-17]Status: DisposedITAT Mumbai24 Dec 2025AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

Section 250

Rs.16,38,56,590/-, by filing its original return of income on 29.11.2016 for the assessment year under consideration, which was selected for complete scrutiny, and therefore, the statutory notice under section 143(2) of the Act was issued on 01.08.2017 by Income Tax Officer (supra). Admittedly accordingly to Instruction

Atishay Jewellers Pvt. Ltd., Delhi vs. ITO Ward 3(4), Delhi

In the result, the appeal of the assessee is allowed

ITA 5714/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Dec 2025AY 2017-18

Section 143(2)Section 143(3)Section 145(3)Section 250Section 68

trading of jewellery, filed its return of income on 30.10.2017, declaring total income of INR 2,82,060/-. The case was selected for complete scrutiny assessment under CASS and statutory notice u/s 143(2) was issued through ITBA and sent to the assessee through speed post. The total turnover

Mall Hotel Limited, Delhi vs. DCIT, Delhi

In the result, the appeal of the assessee is dismissed

ITA 5064/DEL/2025[2018-19]Status: DisposedITAT Delhi24 Dec 2025AY 2018-19

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

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 36(1)(va)

income of Rs. 11,13,11,270/- was e-filed on 30th October, 2018 by the Assessee’s company. The case was selected for complete scrutiny assessment under the e-assessment scheme, 2019 on the issue of verification of genuineness of expenses. Notice under section

Punch Ratna Fasteners Private Limited, Delhi vs. ACIT, Circle 19(1), Delhi

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

ITA 4066/DEL/2025[2018-19]Status: DisposedITAT Delhi24 Dec 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2018-19] Punch Ratna Fasters Vs Acit Pvt.Ltd., 4/8 Third Floor, Circle-19(1) East Punjabi Bagh, Delhi Delhi-110026. Pan-Aaacp1316M Appellant Respondent Appellant By Shri Naveen Gupta, Adv. & Shri Nakul Gupta, Adv. Respondent By Shri Manish Gupta, Sr. Dr Date Of Hearing 24.12.2025 Date Of Pronouncement 24.12.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 16.05.2025 By Ld. Commissioner Of Income Tax (A), Meerut [“Ld.Cit(A)”] In Appeal No. 288/2013-14 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of The Assessment Order Dated 17.02.2021 Passed U/S 143(3) R.W.S. 143(3A) & 143(3B) Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Company Is Engaged In The Business Of Manufacturing Of Cold & Hot Forged Automotive Components & Fasteners & Had Filed Its Return Of Income On 28.10.2018, Declaring Total Income Of Inr 28,88,88,610/-. Subsequently, The Said Return Of Income Was Selected For Complete Scrutiny Under Cass For The Issues Namely, (I) Expenditure Of Personal Nature & (Ii) Foreign Financial Interest. Subsequently, Notice U/S 143(2) Of The Act Was Served Upon The Assessee On 22.09.2019. Thereafter, Notices U/S 142(1) Of The Income-Tax Act 1961 Were Issued, In Response To Which, The Assessee Submitted Copies Of Relevant Documents & Explanations Online Through E- Filing Portal. After Considering The Submissions Made By The Assessee & All Relevant Materials Available On Record, Income Of The Assessee Was Assessed At Inr 29,16,01,890/- Vide Assessment Order Dated 17.02.2021 Passed U/S 143(3) Of The Act.

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 37

return of income on 28.10.2018, declaring total income of INR 28,88,88,610/-. Subsequently, the said Return of Income was selected for Complete scrutiny under CASS for the issues namely, (i) expenditure of personal nature and (ii) foreign financial interest. Subsequently, notice

The Shiroda Progressive Urban Multipurpose Cooperative Society Limited, Ponda vs. Income Tax Officer, Panaji

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

ITA 273/PAN/2025[2020-21]Status: DisposedITAT Panaji23 Dec 2025AY 2020-21

Bench: Shri Pavan Kumar Gadalei T A. Nos.272 & 273/Pan/2025 (A.Y. 2018-19 & 2020-21 ) The Shiroda Progressive Urban Vs I T O, Multipurpose Cooperative National E Assessment . Society Limited, Centre, Shop.No.4, Opp: Police Station, Delhi. Shiroda Bhat, Ponda-403103.Goa Pan .No. Aabat7206P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 80P(2)(a)

after claiming deduction u/sec80P(2)(b)/u/sec80P(2)(d) of the Act of Rs.37,40,896/- and the case was selected for complete scrutiny under the E-assessment Scheme 2019 on the fallowing two issues i.e (i) Investments/Advances/Loans and (ii) Deduction from Total income under chapter V-A. Subsequently

The Shiroda Progressive Urban Multipurpose Cooperative Society Limited, Ponda vs. Income Tax Officer, Panaji

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

ITA 272/PAN/2025[2018-19]Status: DisposedITAT Panaji23 Dec 2025AY 2018-19

Section 80P(2)(a)

Sukla Banerjee, Kolkata vs. ITO, Ward 22(2), Kolkata

In the result, appeal of the assessee is allowed

ITA 1987/KOL/2025[2022-2023]Status: DisposedITAT Kolkata23 Dec 2025AY 2022-2023

Bench: SHRI RAJESH KUMAR (Accountant Member), SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

For Appellant: Shri Soumitra Choudhury, &For Respondent: ShriPradip Kumar Biswas, Sr.DR

Section 142ASection 143(2)Section 153(1)Section 69

filed the return of income for the AY2022-23on 07.09.2022declaring a total income 3 of Rs.30,80,970/-. This case was selected for complete scrutiny the CASS for the following reason: The assessee has reported substantial amount under the head 'Improvement Cost' under Schedule CG of ITR. Here ... nature and do not override the statutory validity of notices issued under the Act. The notice dated 01.06.2023, though not explicitly stating "limited" or "complete" scrutiny, does not vitiate the assessment proceedings unless prejudice is demonstrated. The AO had jurisdiction and the notice was issued within prescribed time. Further

Harish Chand Gupta, Delhi vs. Income Tax Officer, Ward 34(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 671/DEL/2025[2017-18]Status: DisposedITAT Delhi23 Dec 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarassessment Year : 2017-18 Harish Chand Gupta, Vs. Income Tax Officer, Bn-81, West Shalimar Bagh, Ward-34(1), Delhi – 110 088. Delhi. Pan: Aeupg0010Q (Appellant) (Respondent) Assessee By : Shri S.K. Gupta, Ca Revenue By : Shri Om Parkash, Sr. Dr Date Of Hearing : 29.10.2025 Date Of Pronouncement : 23.12.2025

For Appellant: Shri S.K. Gupta, CAFor Respondent: Shri Om Parkash, Sr. DR

Section 142(1)Section 143(1)Section 143(2)Section 144Section 250Section 68Section 69A

derived income under the head ‘Income from business or profession’ ‘income from other sources’ and salary. The case was selected for scrutiny under complete scrutiny for the reasons:- (i) Purchases shown in the ITR is less than the invoices value of imports shown in the export import data. (ii) Custom

Cbre South Asia Private Limited, Delhi vs. Additional, Joint, Deputy, Assistant Commissioner of Income Tax, National Faceless Assessment Centre, Delhi

In the result, the appeal filed by assessee is allowed

ITA 2282/DEL/2024[2019-20]Status: DisposedITAT Delhi23 Dec 2025AY 2019-20

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2019-20 Cbre South Asia Pvt. Ltd., Vs. Additional, Joint, Deputy, Assistant Pti Building, 4, Ground Floor, Commissioner Of Income Tax, Parliament Street Central Delhi, National Faceless Assessment Centre, Parliament House, New Delhi Delhi Pin: 1100 01 Pan :Aaacc9308A (Appellant) (Respondent)

Section 139(5)Section 142(1)Section 143(2)Section 143(3)Section 2Section 250Section 251Section 40A(7)Section 41Section 43A

revised return under Section 139(5) of the Act, declaring income of Rs.1,99,74,55,920/- on 29.09.2020. The case was selected for complete scrutiny under CASS on following issues: i ) Increase in TDS in Revised Return ii) Claim of Any Other Amount Allowable as Deduction in Schedule

Sh. Amrish Singh, Sirsa vs. ACIT/DCIT- Int. Tax, Gurgaon

In the result, appeal of the assessee is allowed

ITA 590/CHANDI/2022[2019-20]Status: DisposedITAT Chandigarh23 Dec 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2018-19 Shri Karan Jeet Singh, Vs. Dcit/Acit, 1, Hisar Road, Vpo- Intl. Taxation, Khairpur, Ward-4, Sirsa, Gurgaon Haryana Pan: Acgps7292E (Appellant) (Respondent) With Assessment Year: 2018-19 Shri Kabal Jeet Singh, Vs. Dcit/Acit, 1, Hisar Road, Vpo- Intl. Taxation, Khairpur, Ward-4, Sirsa, Gurgaon Haryana Pan: Acgps7934M (Appellant) (Respondent) With Ita Nos.390/Chandi/2021 & 590/Chandi/2022 Assessment Year: 2018-19 & 2019-20 Shri Amrish Singh, Vs. Dcit/Acit, 1, Hisar Road, Vpo- Intl. Taxation, Khairpur, Ward-4, Sirsa, Gurgaon Haryana Pan: Aszps6911K (Appellant) (Respondent) Assessee By Sh. Lalit Mohan, Adv. Sh. Ankit Kumar, Adv. Department By Sh. Mahesh Kumar, Cit(Dr) Date Of Hearing 23.12.2025 Date Of Pronouncement 23.12.2025

Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(vii)

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 Lottery/crossword puzzle/horse races. The Ld. Assessing Officer ("AO") served

Shri Kabal Jeet Singh, Sirsa vs. DCIT/ACIT-Int.-Tax, Gurgaon

In the result, appeal of the assessee is allowed

ITA 424/CHANDI/2021[2018-19]Status: DisposedITAT Chandigarh23 Dec 2025AY 2018-19

Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(vii)

Shri Karan Jeet Singh, Sirsa vs. DCIT/ACIT- Int.Tax, Gurgaon

In the result, appeal of the assessee is allowed

ITA 391/CHANDI/2021[2018-19]Status: DisposedITAT Chandigarh23 Dec 2025AY 2018-19

Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(vii)

Sh. Amrish Singh, Sirsa vs. DCIT/ACIT, Int. Tax., Gurgaon

In the result, appeal of the assessee is allowed

ITA 390/CHANDI/2021[2018-19]Status: DisposedITAT Chandigarh23 Dec 2025AY 2018-19

Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(vii)