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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

Dy. Commissioner of Income Tax, Central Circle 3, Delhi vs. Rakesh Arora, Delhi

In the result, the appeal of the Revenue is dismissed

ITA 3610/DEL/2025[2016-17]Status: DisposedITAT Delhi10 Dec 2025AY 2016-17

Bench: Shri Anubhav Sharma& Shri Amitabh Shukla[Assessment Year: 2016-17]

Section 143(3)Section 2(22)(e)Section 69A

given relief on the premises that the ld. AO ought to have converted the limited scrutiny case to complete scrutiny category by taking prior approval of supervisory authority. Before proceeding further, we deem it appropriate to briefly examine the brief factual matrix of the case. As per facts recorded ... verification, the case may be taken up for comprehensive scrutiny with the approval of the Pr. CIT/DIT concerned e. While proposing to take up 'Complete Scrutiny' in a case which was originally earmarked for 'Limited Scrutiny', the Assessing Officer shall be required to form a reasonable view that there

Parveen Batra, Jaipur vs. Circle - 3(1)(1), Muzaffarnagar

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

ITA 3100/DEL/2025[2020-21]Status: DisposedITAT Delhi10 Dec 2025AY 2020-21

Bench: Shri S.Rifaur Rahman & Shri Yogesh Kumar U.S.Parveen Batra, Vs. Acit, Circle 3(1)(1), D – 82B, Siwad Parea, Muzaffarnagar. Krishna Marg, Bapu Nagar, Jaipur – 302 015 (Rajasthan). (Pan : Abwpb1332M) (Appellant) (Respondent) Assessee By : Shri R.S. Punia, Ca Revenue By : Shri Om Prakash, Sr. Dr Date Of Hearing : 17.09.2025 Date Of Order : 10.12.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 04.03.2025 For The Assessment Year 2020-21 Raising Following Grounds Of Appeal :- “1. That Under The Facts & Circumstances Of The Case The Ld. Cit (Appeals), Nfac Has Erred In Law & Facts In Not Condoning The Delay. Kindly Condone The Delay & Treat The Appeal As A Valid Appeal.

For Appellant: Shri R.S. Punia, CAFor Respondent: Shri Om Prakash, Sr. DR
Section 143(2)

filed her return of income for AY 2020-21 on 12.02.2021 declaring total income at Rs.72,86,250/-. The case was selected for complete scrutiny through CASS under Board’s guidelines to examine the issue viz. large commission expenses and low net profit. Accordingly, notices under section

Dabur India Limited, Delhi vs. ACIT/DCIT, Delhi

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

ITA 3085/DEL/2025[2021-22]Status: DisposedITAT Delhi10 Dec 2025AY 2021-22

Bench: Shri S.Rifaur Rahman & Shri Yogesh Kumar U.S.Dabur India Limited, Vs. Acit, Circle 7 (1), 8/3, Asaf Ali Road, Delhi. Delhi – 110 002. (Pan : Aaacd0474C) (Appellant) (Respondent) Assessee By : Shri Chandan Agarwal, Ca Revenue By : Shri Dayainder Singh Sidhu, Cit Dr Date Of Hearing : 17.09.2025 Date Of Order : 10.12.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Addl./Jcit (A), Kochi [“Ld. Jcit(A)”, For Short] Dated 17.03.2025 For The Assessment Year 2021-22 Raising Following Grounds Of Appeal :- “1. That The Ld. Cit(A) Has Erred On Facts & In Law In Holding That The Appeal Filed Against Order Passed U/S 143(1) Is Infructuous As The Order Is Merged With The Assessment Order Passed U/S 143(3) R.W.S 144C(3) R.W.S 144B. 2. That The Order Of The Ld. Cit(A) Is Bad In Law As No Opportunity Of Being Heard Was Granted To The Appellant.

For Appellant: Shri Chandan Agarwal, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 115JSection 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 154Section 35Section 35(1)Section 35(1)(iv)Section 80G

raised a demand of Rs.34,84,16,830/-. Subsequently, the case of the assessee was also selected for scrutiny for complete scrutiny through CASS. Accordingly, the notices under section 143(2) and 142(1) of the Income-tax Act, 1961 (for short ‘the Act’) were issued and served

Society for Advancement of Village Economy, Gaya vs. ACIT(Exemption) Circle, Patna

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

ITA 14/PAT/2018[2014-15]Status: DisposedITAT Patna09 Dec 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 11Section 12ASection 13(8)Section 143(2)Section 2(15)Section 250(6)Section 28

During the course of the assessment proceeding, the details and books of account and vouchers were examined and the limited scrutiny was converted to complete scrutiny with the approval of the competent authority as per the CBDT Instruction No. 5/2016 dated 14.07.2016. The Assessing ITA No.: 14/PAT/2018 Assessment Year

Anmol Himanshu Patel Legal Heir of Late Himanshu Raojibhai Patel, Vadodara vs. The ITO, Ward-1(1)(4) Now Present Jurisdiction the Dy.CIT, Circle-1(1)(1), Vadodara

In the result, the appeal of the assessee stands allowed

ITA 1479/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2015-16

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.1479/Ahd/2025 िनधा"रण वष" /Assessment Year : 2015-16 Anmol Himanshu Patel The Ito बनाम/ (Legal Heir Of Late Himanshu Ward-1(1)(4) V/S. Raojibhai Patel) Now Present Jurisdiction Bs/B-7, Indraprasth Complex The Dy.Cit, Circle-1(1)(1) Nr. Inox Race Course Circle Vadodara – 390 007 Vadodara – 390 007 "थायी लेखा सं./Pan: Acqpp 6460 P (अपीलाथ'/ Appellant) (!( यथ'/ Respondent) Assessee By : Shri Biren Shah, Ar Revenue By : Shri B.P. Srivastava, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 18/09/2025 घोषणा की तारीख /Date Of Pronouncement: 09/12/2025 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 10/06/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2015-2016. 2. The Assessee, In This Appeal, Has Raised The Following Grounds Of Appeal: Anmol Himanshu Patel (Legal Heir Of Late Himanshu Raojibhai Patel) Vs. Dcit Asst.Year 2015-16. “1. In Law & In The Facts & Circumstances Of The Case Of The Appellant, The Order Passed By The Cit(A) U/S 250 Of The Act Is Bad In Law & Deserves To Be Quashed.

For Appellant: Shri Biren Shah, ARFor Respondent: Shri B.P. Srivastava, Sr.DR
Section 2(22)(e)Section 250

relevant parameters which formed the basis for selecting the case for scrutiny However, in revenue potential cases, it was further provided that Complete Scrutiny could be conducted, if there was potential escapement of income above a prescribed monetary limit, subject to the approval of administrative Pr. CIT/CIT/Pr. DIT/DIT. 2.In order ... ensure that maximum objectivity is maintained in converting a case falling under Limited Scrutiny' into a Complete Scrutiny case, the matter has been further examined and in partial modification to Para 3(d) of the earlier order dated 29.12.2015, Board hereby lays down that while proposing to take up Complete

Ghodawat Skystar LLP (Formerly Ghodawat Consumer Products LLP), Kolhapur vs. DCIT Circle 1, Kolhapur

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

ITA 1400/PUN/2025[2018-19]Status: HeardITAT Pune09 Dec 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Ghodawat Skystar Llp Dcit, Circle – 1, Kolhapur (Formerly Ghodawat Consumer Products Llp) Vs. Plot No.438, Ap Chipri Via Jaysingpur Shirol, Kolhapur – 416101 Pan: Aamfg7028C (Appellant) (Respondent) Assessee By : Shri B S Rajpurohit Department By : Shri Rajesh Gawali, Addl.Cit Date Of Hearing : 08-12-2025 Date Of Pronouncement : 09-12-2025 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri B S RajpurohitFor Respondent: Shri Rajesh Gawali, Addl.CIT
Section 142(1)Section 143(1)Section 143(2)

return was processed u/s 143(1) of the Income Tax Act, 1961 (hereinafter referred to as ‘the 2 Act’) and subsequently selected for complete scrutiny assessment through CASS. Accordingly, statutory notice u/s 143(2) of the Act was issued and served on the assessee. Subsequently notice

Aqua Tech Solutions Private Limited, Pune vs. PCIT (Central)-3, Mumbai

In the result, the appeal of the assessee is allowed

ITA 3855/MUM/2025[2018-19]Status: DisposedITAT Mumbai09 Dec 2025AY 2018-19

Bench: Shri Saktijit Dey & Ms Padmavathy S, Acccountant Member

For Appellant: Ms. Simran Dhawan &For Respondent: Shri. Rajesh Kumar Yadav, CIT. DR
Section 143(3)Section 263Section 263(1)Section 801A(4)

deduction u/s 801A(4) was already examined and allowed in the previous assessment order passed u/s 143(3) of the Act on 17.05.2021 after complete scrutiny under CASS, with reference to which, the limitation for revision u/s 263 already expired on 31.03.2024. 3. On the facts and in the circumstances

Deputy Commissioner of Income Tax, City Centre, Gwalior vs. Sheeladevi Narwariya, Gwalior Road Mehagaon

In the result, the revenue’s appeal is dismissed

ITA 403/AGR/2025[2017-18]Status: DisposedITAT Agra08 Dec 2025AY 2017-18

Bench: : Shri M. Balaganesh & Shri Sunil Kumar Singhassessment Year: 2017-18

Section 143(2)Section 250Section 69A

that the assessee e-filed her return of income on 28.10.2017, declaring total income of Rs.27,89,960/-. The case was selected for complete scrutiny under CASS. Statutory notices u/s. 143(2) and 142(1) of the Act were issued and served upon assessee. Assessee filed her submissions on ITBA

Gopaljee Prasad, Darbhanga vs. Dc/Ac Cir-3, Darbhanga

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

ITA 465/PAT/2024[2015-16]Status: DisposedITAT Patna08 Dec 2025AY 2015-16

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 133ASection 143(2)Section 143(3)Section 250

proprietor of M/s. Swarnalaya Jewellers and had filed his income tax return showing total income of ₹74,41,260/-. The case was selected for complete scrutiny under the manual category and notices u/s 143(2) and 142(1) of the Act were issued, in response to which the assessee submitted

Income Tax Officer-2(1)(4), Rudrapur vs. Swarnim Promoters & Developers, Rudrapur

In the result, the appeal of the Revenue is dismissed

ITA 55/DDN/2025[2018-19]Status: DisposedITAT Dehradun05 Dec 2025AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalincome Tax Officer-2(1)(4), Swarnim Promotoers & Rudrapur. Developers, Vs. Mandi Parisar Kichha Road, Rudrapur, Uttarakhand. Pan: Abqfs9375M (Appellant) (Respondent) Assessee By Shri Amit Goel, Ca & Shri Pranav Yadav, Adv. Department By Shri Amar Pal Singh, Sr. Dr Date Of Hearing 11/09/2025 Date Of Pronouncement 05/12/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Revenue Against The Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (‘The Cit(A) In Short) Passed U/S 250 Of The Income Tax Act, 1961, Dated 06.02.2025 For Assessment Year 2018-19. 2. The Brief Facts Of The Case Are That The Assessee Is A Partnership Firm Engaged In The Business Of Real Estate. The Return Of Income Was E-Filed On 17.10.2018 Declaring Total Income At Rs.2,89,400/-. The Case Of The Assessee Was Selected For Complete Scrutiny & The Assessing Officer Has Computed The Total Income At Rs.1,27,38,630/- Vide Order Passed U/S 143(3) R.W.S. 144B Of The Act Dated 02.06.2011 By Making The Following Additions/Disallowances:

Section 143(3)Section 250Section 37Section 68

return of income was e-filed on 17.10.2018 declaring total income at Rs.2,89,400/-. The case of the assessee was selected for complete scrutiny and the Assessing Officer has computed the total income at Rs.1,27,38,630/- vide order passed u/s 143(3) r.w.s. 144B

Dy Commissioner of Income Tax Circle 5 Pune, Pune vs. Dipti Narendra Lulla, Pune

ITA 1065/PUN/2025[2018-19]Status: DisposedITAT Pune05 Dec 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

Section 143(2)

filed her return of income on 26.09.2018 declaring total income of Rs.2,81,03,870/-. The case of the assessee was selected for complete scrutiny through CASS on the following issues: “S. No. i. ii. iii. Issues Refund Claim Unsecured Loans Business Expenses” 3. Accordingly statutory notices

Anil Kumar Dundoo, Secunderabad vs. ACIT., Circle-10(1), Hyderabad

In the result, the appeal of the assessee is dismissed

ITA 1470/HYD/2025[2017-2018]Status: DisposedITAT Hyderabad05 Dec 2025AY 2017-2018

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1470/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Anil Kumar Dundoo Vs. Acit Secunderabad Circle 10(1) Pan:Abppd7600K Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate D Prabhakar Reddy राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 26/11/2025 घोषणा की तारीख/Pronouncement: 05/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Advocate D Prabhakar ReddyFor Respondent: : Dr. Sachin Kumar, Sr. DR
Section 143(2)Section 143(3)

assessment year 2017-18 on 04.11.2017 admitting a total income of Rs.49,59,100/-. The case of the assessee was selected for complete scrutiny under CASS and accordingly notice under section 143(2) of the Income Tax Act, 1961 (“the Act”) dated 09.08.2018 was issued by the Learned Assessing Officer

Damodaram Suresh, Gobichettipalayam vs. ITO, Ward 1(1), Erode

In the result, the appeal of the assessee is dismissed

ITA 2715/CHNY/2024[2017-18]Status: DisposedITAT Chennai05 Dec 2025AY 2017-18

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble S.R. Raghunathaआयकर अपील सं./ Ita No.2715/Chny/2024 ननिाारण वर्ा /Assessment Year: 2017-18 Damodaran Suresh, The Income Tax Officer, Prop. Sumy Electronic, Vs. Ward-1(1), No.52, Main Road, Erode. Gobichettipalayam Tamil Nadu - 638 452. [Pan: Aijps3460M] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.Girish Kumar, Advocate प्रत्यर्थी की ओर से /Respondent By : Mr.Bipin, C.N, Cit सुनवाई की तारीख/Date Of Hearing : 08.09.2025 घोर्णा की तारीख /Date Of Pronouncement : 05.12.2025 आदेश / O R D E R Per Manu Kumar Giri (): The Captioned Appeal Filed By The Assessee Is Directed Against Order Of The Ld. Principal Commissioner Of Income Tax, Coimbatore-1 [Pcit] Dated 09.02.2024 For Assessment Year 2017-18. 2. There Is A Delay Of 198 Days In Filing This Appeal. The Assessee Has Filed Petition Along With Affidavit For Condonation Of Delay Stating Damodaram Suresh :- 2 -: Therein The Reasons For Belated Filing Of The Appeal. On Perusal Of The Aforesaid Reasons In The Condonation Application, We Are Of The View That There Is Sufficient Cause For Belated Filing Of This Appeal. Hence, We Condone The Delay In Filing This Appeal & Proceed To Dispose Of The Appeals On Merits.

For Appellant: Mr.Girish Kumar, AdvocateFor Respondent: Mr.Bipin, C.N, CIT
Section 143(3)Section 263Section 4Section 40A(3)

income for the A.Y. 2017-18 on 25/10/2017 admitting total income of Rs.4,99,950/-. The case was selected for scrutiny through CASS for complete scrutiny and the assessment was completed u/s 143(3) of the Income Tax Act, 1961 vide order dated 31/12/2019 arriving at a total income

Trifecta Projects Private Limited, Bengaluru vs. DCIT, Central Circle-2(2), Bangalore

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

ITA 918/BANG/2025[2020-21]Status: DisposedITAT Bangalore05 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2020-21

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR
Section 132Section 143(1)Section 143(2)Section 153ASection 271ASection 274Section 37Section 40ASection 40A(3)

normal course of business, the assessee had maintained the books of accounts in which the expenditures were claimed but while making the complete scrutiny, the AO had disallowed the said expenditure by saying that the cash payments exceeds Rs. 20,000/-. Therefore the fact remains that the assessee had recorded

ACIT, CC, Agra vs. Hma Agro Industries Limited, Agra

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 303/AGR/2025[2023-24]Status: DisposedITAT Agra04 Dec 2025AY 2023-24

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

assessee filed its return of income declaring income of Rs. 48,41,83,500/- for the year under consideration and the first complete scrutiny assessment was framed, wherein addition to the tune of Rs. 1,08,00,000/- was made on assessee relating to excess salary paid to two employees

ACIT, CC, Agra vs. Hma Agro Industries Limited, Agra

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 301/AGR/2025[2021-22]Status: DisposedITAT Agra04 Dec 2025AY 2021-22

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

assessee filed its return of income declaring income of Rs. 48,41,83,500/- for the year under consideration and the first complete scrutiny assessment was framed, wherein addition to the tune of Rs. 1,08,00,000/- was made on assessee relating to excess salary paid to two employees

Hma Agro Industries Limited, Agra vs. Deputy Commissioner of Income-Tax, Central Circle, Agra

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 251/AGR/2025[2018-2019]Status: DisposedITAT Agra04 Dec 2025AY 2018-2019

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

assessee filed its return of income declaring income of Rs. 48,41,83,500/- for the year under consideration and the first complete scrutiny assessment was framed, wherein addition to the tune of Rs. 1,08,00,000/- was made on assessee relating to excess salary paid to two employees

Chintan Umedsinh Sodha, Jamnagar vs. Income Tax Officer, Ward 1(3), Jamnagar

In the result, appeal filed by the assessee is partly allowed in above terms

ITA 246/RJT/2024[2016-17]Status: DisposedITAT Rajkot04 Dec 2025AY 2016-17

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.246/Rjt/2024 िनधा"रण वष"/Assessment Year : 2016-17 बनाम Chintan Umedsinh Sodha Income Tax Officer “Het” Chitrkutt Society, / Ward – 1(3), Jamnagar Plot No. 21-22, Vs Opp. Khodiyar Co, Jamnagar- 361 006 Gujrat India "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Avgps4814B (अपीलाथ"/Assessee) (""थ"/Respondent)

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 133(6)Section 142(1)Section 143Section 143(2)Section 143(3)Section 250

year under consideration and the same was processed u/s 143 (1) of the I.T. Act. Thereafter, assessee`s case was selected for complete scrutiny under CASS and statutory notice u/s 143(2) was issued on 04/7/2017. Further notice u/s 142(1) r.w.s. 129 dated 08/09/2018 was issued due to change

DCIT, Swargate Pune vs. Cummins India Ltd, Pune

In the result, appeal of the assessee bearing ITA No

ITA 1256/PUN/2023[2018-19]Status: DisposedITAT Pune04 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Ms. Astha Chandra

Section 10ASection 115JSection 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(5)Section 14ASection 250Section 35

such relief granted by Ld. CIT(A), Revenue is in appeal vide ITA No. 1256/PUN/2023. Further, post selection of the assessee's case for complete scrutiny, a final assessment order u/s. 143(3) r.w.s.144C(13) of the Act has been framed on 30/06/2022 making various additions and adjustments against which ... 10AA at Rs.196,96,24,249/-, both on account of delay in filing return of income. Subsequently, case selected for scrutiny through CASS under complete scrutiny category and valid statutory notices u/s.143(2) of the Act were served. The assessee company is engaged in manufacturing and sale of Internal Combustion

Cummins India Limited, Pune vs. Assistant Commissioner of Income-Tax, Circle - 1(1), Pune

In the result, appeal of the assessee bearing ITA No

ITA 632/PUN/2022[2018-19]Status: DisposedITAT Pune04 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Ms. Astha Chandra

For Appellant: Shri J.D. Mistri, Sr. Advocate &For Respondent: Shri Prakash L. Pathade, CIT-DR
Section 10ASection 13Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(5)Section 14ASection 250Section 80J

such relief granted by Ld. CIT(A), Revenue is in appeal vide ITA No. 1256/PUN/2023. Further, post selection of the assessee’s case for complete scrutiny, a final assessment order u/s. 143(3) r.w.s. 144C(13) of the Act has been framed on 30/06/2022 making various additions and adjustments against ... both on account of delay in filing return of income. Subsequently, case selected for scrutiny through CASS under complete scrutiny category and valid statutory notices u/s. 143(2) of the Act were served. The assessee company is engaged in manufacturing and sale of Internal Combustion Engines