“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

Belathur Srinivasaiyengar Rangaiyengar, Mysore vs. Income Tax Officer, Ward-1(1), Mysore

In the result, appeal of the assessee is allowed

ITA 574/BANG/2025[2017-18]Status: DisposedITAT Bangalore16 Dec 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Sri Lokanath S., A.RFor Respondent: Sri Balusamy N., D.R

Section 143(2)Section 143(3)Section 250Section 269SSection 44A

case are that the assessee filed his return of income for the assessment year 2017-18 on 3.8.2017. Thereafter, the case was selected for complete scrutiny under CASS and accordingly notices u/s 143(2) as well as 142(1) of the Act were issued calling for the various documents/record

Deputy Commissioner of Income Tax, Circle 3(1)(1), Bengaluru vs. Nutricraft India Private Limited, Bengaluru

In the result appeal filed by the learned assessing officer is partly allowed for statistical purposes

ITA 298/BANG/2024[2017-18]Status: DisposedITAT Bangalore16 Dec 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Muthu Shankar, CIT(DR)(ITAT), BengaluruFor Respondent: Smt. Suman Lunkar, CA

Section 143(3)Section 148ASection 153CSection 194C(6)Section 194C(7)Section 36(1)(ii)Section 40

animal feeds. It filed its return of income on 29/11/2017 with the returned income of ₹ 65,777,280/–. The case was selected for the complete scrutiny. 13. The ld. AO found that assessee has paid a remuneration to its director amounting to ₹ 11,39,00,000/- which

Shri Sureshkumar Harjivanbhai Chandarana, Rajkot vs. The ACIT, Circle - 2 (2) (1), Rajkot

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

ITA 415/RJT/2023[2016-17]Status: HeardITAT Rajkot15 Dec 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 415/Rjt/2023 (िनधा"रण वष"/Assessment Year: (2016-17) Sureshkumar Harjivanbhai Chandarana Acit, Circle – 2(2)(1), Rajkot A-75, New Market Yard, Village-Bedi, Vs. Aayakar Bhavan, Race Course Ring Morbi, Highway, Rajkot- 360 003 Road, Rajkot –360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abcpc8536E (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Mehul Ranpura, Ld. Ar Respondent By : Shri Durga Dutt, Ld. Cit(Dr) Date Of Hearing : 27/11/2025 : 15/12/2025 Date Of Pronouncement Order Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay) 2016-17, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By Commissioner Of Income-Tax, Appeal Cit(A), Ahmedabad-13 Dated 06.10.2023 [In Short, “Ld. Cit(A)”], Which In Turn Arises Out Of An Order Passed By The Assessing Officer U/S 143(3) R.W.S. 144C(3) Of The Act, Vide Order Dated 19.12.2019. 2. Grounds Of Appeal Raised By The Assessee, Are As Follows:

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Durga Dutt, Ld. CIT(DR)

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

return of income was processed u/s 143(1) of the Income-tax Act on the returned income. The case was selected for Complete Scrutiny through CASS. Accordingly, notice u/s 143(2) of the Act was issued on 20.09.2017, which was duly served upon the assessee. Another notices

Avon Cycles Limited, G.T Road, Dhandari Kalan, Ludhiana vs. Pr. Commissioner of Income Tax, 1, Rishi Nagar, Ludhiana

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

ITA 705/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh15 Dec 2025AY 2021-22

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं/. Ita No. 705/Chd/2025 िनधा"रणवष" / Assessment Year: 2021-22 Avon Cycles Ltd., Vs The Pcit-I, G.T.Road, Dhandari Kalan, Rishi Nagar, Ludhiana. Ludhiana. "थायीलेखासं/.Pan No: Aabca4140R अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashish Aggarwal, Ca Revenue By : Shri Manav Bansal, Cit, Dr Date Of Hearing : 09.12.2025 Date Of Pronouncement : 15/12/2025 Physical Hearing Order Per Laliet Kumar, Jm This Appeal Filed By The Assessee Is Directed Against The Order Of The Principal Commissioner Of Income Tax, Ludhiana-1 (Hereinafter Referred To As The "Pcit"), Dated 27.03.2025, Passed Under Section 263 Of The Income Tax Act, 1961 (The "Act") For The Assessment Year 2021-22. 2. The Assessee Has Raised The Following Substantive Grounds Of Appeal: “1. That Ld. Pcit -1, Ludhiana, Erred In Law & On Facts In Assuming The Jurisdiction To Invoke The Provisions Of Section 263 Of The Act To Set Aside The Order Passed By The Assessing Officer (National Faceless Assessment Centre, Delhi) When The Order Was Neither Erroneous Nor Prejudicial To The Interest Of Revenue. The Order Passed By Ld. Pcit(1), Ludhiana, Being Illegal Unjustified & Against The Provisions Of Section 263 May Be Annulled. 2. That Ld. Pcit (1) Erred In Law & On Facts In Setting Aside The Order Of Assessing Officer (National Faceless Assessment Centre, Delhi) By Applying The Different Approach On The Same Set Of Facts On The Issues Already Considered By The Assessing Officer.

For Appellant: Shri Ashish Aggarwal, CAFor Respondent: Shri Manav Bansal, CIT, DR

Section 143(3)Section 194JSection 263Section 69C

Assessing Officer (AO), and therefore, the AO had no occasion to form an opinion on it. Since the assessment was subject to complete scrutiny, it was incumbent upon the AO to examine this issue. The failure of the AO to do so is deemed to be an error and renders ... prejudicial to the interests of the Revenue. 13.3 The ld. DR had drawn our attention to the assessment order, where the primary reason for complete scrutiny was mentioned as stock valuation. Further the ld. DR had drawn our attention to the question posed by the AO at page

Harshvardhan T.Soni, Dahod vs. The ACIT, Panchamahal Circle, Godhra Present Jurisdiction the ACIT., Anand Circle, Anand

In the result, the appeal of the assessee is allowed

ITA 171/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad15 Dec 2025AY 2017-18

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

For Appellant: Shri M K Patel, AdvocateFor Respondent: Shri Ravindra, Sr. DR

Section 250Section 271ASection 68

return of income for the year under consideration on 16.10.2017, declaring a total income of Rs.13,48,890/-. The case was selected for complete scrutiny under CASS. 4. During assessment proceedings, the Assessing Officer noticed that the assessee had deposited cash of Rs.1,10,00,000/- in his bank account

Aadarsh Surana, Chennai vs. Deputy Commissioner of Income Tax, Corporate Circle 1(1), Chennai

In the result, the appeal of the assessee is allowed

ITA 1840/CHNY/2025[2017-18]Status: DisposedITAT Chennai15 Dec 2025AY 2017-18

For Appellant: Shri. R.Venkata Raman, C.AFor Respondent: Shri. Shiva Srinivas, CIT

Section 142(1)Section 143(2)Section 143(3)Section 250Section 47Section 68

Chennai, is bad in law, void ab initio, and without jurisdiction, inasmuch as the Assessing Officer has converted the case from 'limited scrutiny' to 'complete scrutiny' without obtaining the mandatory prior approval of the Principal Commissioner of Income Tax (PCIT) as required under the relevant CBDT Instructions and Circulars ... assessment without obtaining the mandatory approval of the PCIT, thereby acting contrary to binding CBDT Instructions prohibiting unauthorized conversion of limited scrutiny cases into complete scrutiny. On this ground, the assessee urged that the assessment order was void ab initio and liable to be quashed. 20. The assessee additionally brought

Kasturi Medical Centre Private Limited, Joka, Thakurpukur vs. Additional/Joint/Deputy/Assisstant Commissioner of Income Tax/Income-Tax Officer, Delhi

In the result the appeal of the assessee is allowed

ITA 318/KOL/2025[2018-19]Status: DisposedITAT Kolkata12 Dec 2025AY 2018-19

Bench: Shri Manunatha G & Shri Sonjoy Sarmai.T.A. No.318/Kol/2025 Assessment Year: 2018-19 Kasturi Medical Centre Pvt. Ltd……………….................................……….…Appellant 5, Diamond Harbour Road, 3A Bus Stand, Joka, Thakurpukur, W.B – 700104. [Pan: Aacck1872F] Vs. Acit, Nfac, Delhi…….…………..…………….…..….......……..…...…..…..Respondent Appearances By: Shri Indernil Banerjee, Fca, Appeared On Behalf Of The Revenue. Shri Soumitra Ghosh, Sr. Dr, Appeared On Behalf Of The Assessee. Date Of Concluding The Hearing : September 16, 2025 Date Of Pronouncing The Order : December 12, 2025 Order Per Sonjoy Sarma: This Appeal Is Filed By The Assessee Against The Order Of The Learned Cit(A) Passed For The Assessment Year 2018–19, Whereby The Addition Of ₹85,40,911 Made By The Assessing Officer On Estimated Basis After Rejection Of Books Of Account Under Section 145(3) Of The Income-Tax Act, 1961 Was Confirmed. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For Ay 2018–19 Declaring Total Income Of ₹2,05,59,220. The Case Was Selected For Complete Scrutiny Under The Scrutiny Assessment Scheme, 2019, Primarily On The Issue Of Large Refund Claimed Out Of Advance Tax. Accordingly, Notices Under Section 143(2) & Section 142(1) Of The Act Along With Questionnaires Were Duly Issued & Served.

Section 142(1)Section 143(2)Section 145(3)

assessee filed its return of income for AY 2018–19 declaring total income of ₹2,05,59,220. The case was selected for complete scrutiny under the Scrutiny Assessment Scheme, 2019, primarily on the issue of large refund claimed out of advance tax. Accordingly, notices under section

S D Developers, Kolkata vs. ITO, Ward 43(1), Kolkata

ITA 2190/KOL/2025[2018-2019]Status: DisposedITAT Kolkata12 Dec 2025AY 2018-2019

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubey

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

income for AY 2018-19 on 29/09/2018 declaring total income of Rs. 28,69,880/-. The case of the assessee was selected for complete scrutiny through CASS and notices u/s 143(2) & 142(1) of the Act were issued calling for various information. During the course of the assessment proceedings ... income for AY 2018-19 on 29/09/2018 declaring total income of Rs. 28,69,880/-. The case of the assessee was selected for complete scrutiny through CASS and notices u/s 143(2) & 142(1) of the Act were issued calling for various information. During the course of the assessment proceedings

Telstra Singapore Pte Ltd, Singapore vs. Deputy Commissioner of Income Tax, Circle 3(1)(1), International Taxation, Delhi

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

ITA 785/DEL/2025[2022-23]Status: DisposedITAT Delhi12 Dec 2025AY 2022-23

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2022-23 Telstra Singapore Pte Ltd., Vs. Dcit, Circle-3(1)(1), 8 Cross Street, 22-00, Manulife International Taxation, Tower, Singapore New Delhi Pan :Aadct5366N (Appellant) (Respondent)

Section 143(3)Section 144CSection 270ASection 9(1)(vi)

that the appellant/assessee filed its return of income on 23-12-2022 declaring total income at Rs.1,95,520/-. The case was taken under complete scrutiny under CASS. Notices under Section 143(3) was served on 30.06.2023. Thereafter various notices were issued to the assessed. The appellant/assessee furnished responses

Salwan Education Trust, New Delhi vs. DCIT, Exmp 2(1), Delhi

In the result, the appeal of the assessee is allowed as above

ITA 5275/DEL/2024[2018-19]Status: DisposedITAT Delhi12 Dec 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh[Assessment Year: 2018-19] Salwan Education Trust, Dcit, Salwan Schools Campus, Pt Exemption 2(1), Girdhari Lal Salwan Marg, Vs Delhi, Rajinder Nagar, 24Th Floor, Civic Centre, New Delhi-110060, New Delhi-110002. Pan- Aacts9741A Assessee Revenue

Section 11(1)Section 11(2)Section 12ASection 143(2)Section 143(3)

income for the AY 2018-19 on 10/09/2018 admitting NIL income. The case was ITA No.- 5275/Del/2024 Salwan Educa"on Trust selected for complete scrutiny to examine accumulation of income of the Trust and receipts of the Trust. Notice u/s 143(2) was issued on 22.09.2019, and duly served upon

Corteva Agriscience Seeds Pvt. Ltd.(Formerly Known As Phi Seeds Private Limited), Telangana vs. ACIT, Circle-4(2), New Delhi

The appeal of the assessee is allowed

ITA 1422/DEL/2023[2016-17]Status: DisposedITAT Delhi12 Dec 2025AY 2016-17

Bench: Shri S Rifaur Rahman & Shri Anubhav Sharmacorteva Agriscience Vs. Additional/Joint/Deputy Seeds Pvt. Ld. (Formerly Assistant Commissioner Of Known As Phi Seeds Pvt. Ltd.) Income Tax, Circle 4(2) V- Ascendas, Atria Block, Cr Building 12Th Floor, Plot 17, New Delhi Software Units Layout, Madhapur, Hyderabad Telangana India – 500081 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaccp3920F Appellant .. Respondent

For Appellant: Sh. Sandeep Bansal, CAFor Respondent: Ms. Pooja Swaroop, CIT, DR

Section 10Section 10(1)Section 143Section 143(3)Section 2Section 270ASection 271(1)(c)

income for the A.Y. 2016- 17 on 30.11.2016 admitting therein total income of Rs.51,57,14,370/- Subsequently its case was selected for complete scrutiny and assessment u/s 143(3) was made on 12.12.2018 at total income of Rs. 3,39,86,48,800/-. While finalizing the assessment, the following

Subhash Jaiswal Associates, Bareilly vs. PCIT Bareilly, Bareilly

ITA 100/LKW/2022[2017-18]Status: DisposedITAT Lucknow11 Dec 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

For Appellant: Respondent by

Section 143(3)Section 263

account of VAT in the P & L A/c but no documentary evidences is available on file. ix. The case was picked up for complete scrutiny. However, besides routine queries made, no concerted effort seems to have been made to examine the Books of accounts. No third party enquiries have been ... same as the assessing officer who was in charge of the case at the time. 4. This case was picked up for complete scrutiny and the CASS selections reason was: a) Large Cash deposited during demonetization period The assessee AOP deals in retail liquor business. On examination of records

Heta Rawal Legal Heir of Late Shri Shailesh Induprasad Rawal, Vadodara vs. The Dy.CIT, Circle-1(1)(1), Vadodara

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

ITA 281/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad11 Dec 2025AY 2013-14

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2013-14

Section 143(3)Section 250Section 54F

declaring total income of Rs.89,32,010/- which was subsequently revised to income of Rs.89,84,450/-. The case was selected for complete scrutiny under Heta Rawal LH of Lt. Shri Shailesh Induprasad Rawal vs DCIT Page 2 of 5 CASS. In the return, the assessee had disclosed Long Term

Ankur Dealcom P. Limited, Kolkata vs. ITO, Ward 10(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2204/KOL/2025[2021-2022]Status: DisposedITAT Kolkata11 Dec 2025AY 2021-2022

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.2204/Kol/2025 (निर्धारण वर्ा / Assessment Year : 2021-2022) Ankur Dealcom P. Limited, Vs Ito Ward-10(2), Kolkata C/O S.N.Ghosh & Associates, Advocates, 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kolkata-700001 Pan No. :Aahca 2447 F (अपीलधर्थी /Appellant) (प्रत्यर्थी / Respondent) .. निर्धाररती की ओर से /Assessee By Shri Somnath Ghosh, Ar रधजस्व की ओर से /Revenue By : None सुनवाई की तारीख / Date Of Hearing : 11/12/2025 घोषणा की तारीख/Date Of Pronouncement : 11/12/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 22.07.2025 For The Assessment Year 2021-22. 2. It Was Submitted By The Ld.Ar That The Impugned Assessment Order Would Not Survive, Insofar As In The Order U/S.263 Of The Act Against The Said Assessment Order, The Coordinate Bench Of The Tribunal Has Categorically Held That The Notice U/S.143(2) Of The Act, Dated 20.06.2022 Which Is Culminated In The Assessment Order Dated 23.12.2022, Which Is An Impugned Assessment Order Would Not Survive, Insofar As Notice U/S.143(2) Of The Act Was Not In Conformity With The Cbdt Instruction F.No.225/157/2017/Ita-Ii Dated 23-06-2017. It Was The Submission That As Against The Order U/S.263 Of The Act The Coordinate Bench Of The Tribunal

For Respondent: None

Section 12ESection 143(2)Section 143(3)Section 263

instruction, the notice u/s 143(2) has to be in any of the three formats namely; (i) Limited Scrutiny (Computer Aided Scrutiny Selection) (ii) Complete Scrutiny (computer Aided Scrutiny Selection) and (iii) Compulsory Manual Scrutiny. Since, the notice has been issued in an invalid format which is obviously invalid ... assessment proceedings in a widespread manner from this financial year. The three formats of notice(s) are: Limited Scrutiny (Computer Aided Scrutiny Selection) Complete Scrutiny (Computer Aided Scrutiny Selection) 4 Compulsory Manual Scrutiny The revised format of 143(2) notice(s) with a note on benefits & Procedures of 'EProceeding' facility

M/S. Tega Industries Limited, Kolkata vs. D.C.I.T., Circle - 11(1), Kolkata

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

ITA 1875/KOL/2024[2020-2021]Status: DisposedITAT Kolkata11 Dec 2025AY 2020-2021

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 144Section 144C(5)Section 92BSection 92CSection 92C(3)

resistant lining components required for grinding, sizing and beneficiation of minerals, and downstream equipment used in the aforesaid industries. The case was selected for complete scrutiny assessment through Computer Aided Scrutiny Selection System (CASS). Accordingly, notice u/s 143(2) dated 29.06.2021 was issued to the assessee for compliance

Sahade vs. Inh Vajesinh Vaghela, Rajkotvs.PCIT, Rajkot-1, Rajkot

In the result, the appeal of the assessee is allowed

ITA 313/RJT/2024[2018-19]Status: DisposedITAT Rajkot10 Dec 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. A.RFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)

Section 143(3)Section 263Section 40A(3)

return of income for A.Y. 2018-19 on 31/10/2018 declaring total income of Rs.NIL (loss of Rs.9,46,780/-). The case was selected for complete scrutiny. The Assessment was finalised 143(3) rw.s. 143(3A) & 143(3B) of the LT. Act, 1961 on 12.04.2021 accepting returned income

Ct Educational Society, Jalandhar vs. DCIT, Chandigarh

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

ITA 422/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh10 Dec 2025AY 2017-18

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashray Sarna, CA(Virtual Mode)For Respondent: Shri Manav Bansal, CIT, DR

Section 11Section 143Section 143(3)Section 144B

that the assessee, CT EDUCATIONAL SOCIETY , a registered TRUST , filed its Return of Income on 28/10/2017 declaring NIL income. The case was selected for Complete Scrutiny assessment under the E-assessment Scheme, 2019, focusing on the "Receipts of trust". The total receipts shown by the assessee amounted

Ilyasbhai Kasambhai Rathod, Chhotaudepur vs. The ITO, Ward-3(1)(4) (Previously Ward-3(1)(5)), Vadodara

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

ITA 1311/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad10 Dec 2025AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2017-18

Section 142(1)Section 143(2)Section 143(3)Section 144Section 44ASection 69A

filed his return of income for the A.Y. 2017-18 on 20.02.2018 declaring total income of Rs.3,50,070/-. The case was selected for complete scrutiny through CASS by issuing notice under Section 143(2) of the Act dated 21.09.2018. Thereafter, notices under Section 142(1) of the Act along

ACIT., Circle-5(1), Hyderabad vs. Pragnapur Developers Private Limited, Hyderabad

Accordingly, the grounds Nos. 1 to 12 are partly allowed

ITA 441/HYD/2025[2022-23]Status: DisposedITAT Hyderabad10 Dec 2025AY 2022-23

Bench: Us:

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

declaring an income of Rs. 6,36,34,062/-. Subsequently, the case of the assessee company was selected for complete scrutiny under CASS for verifying the substantial amount that it had claimed to have incurred under the head “Cost of Improvement”, as was disclosed in “Schedule CG” of its return

Yugendar Puppala, Warangal vs. ACIT., Circle-1, Warangal

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

ITA 1329/HYD/2025[2015-16]Status: HeardITAT Hyderabad10 Dec 2025AY 2015-16

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1329/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2015-16) Ms. Yugendra Puppala Vs. Assistant Commissioner Of Warangal Income Tax Pan:Abspp4161E Circle-1, Warangal (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri G. Srinivasa Rao, Ca राज" व "ारा/Revenue By:: Shri Waseem Ur Rehman, Sr.Dr सुनवाई की तारीख/Date Of Hearing: 04/12/2025 घोषणा की तारीख/Pronouncement: 10/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri G. Srinivasa Rao, CAFor Respondent: : Shri Waseem UR Rehman, Sr.DR

Section 142(1)Section 143(2)Section 143(3)Section 144Section 145(3)

only two issues out of the various grounds raised in this appeal. The first is a legal issue regarding conversion of Limited Scrutiny into Complete Scrutiny without obtaining approval from the competent authority. The second issue relates to estimation of net profit at 3% on the gross receipts of Rs.30 ... Limited Scrutiny. Therefore, the Ld. AR submitted that the action of the Ld. AO in examining purchases without conversion of Limited Scrutiny into Complete Scrutiny is illegal. 7. As regards the second issue, the Ld. AR submitted that the Ld. AO has not given any working, reasoning, or basis