“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

Maharashtra Maritime Board, Mumbai vs. Deputy Commissioner of Income Tax - Exem. Circle 2, Mumbai

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

ITA 8936/MUM/2025[2021-22]Status: DisposedITAT Mumbai13 Mar 2026AY 2021-22

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri Rajesh Kumar Yadav, CIT-DR

Section 11Section 143(1)Section 143(2)Section 143(3)Section 2(15)Section 250

exemption u/s 11 of the Act and the same was processed u/s 143(1) of the Act. The assessee’s case was selected for complete scrutiny for the reason large receipts reported by trust for “charitable purpose”. Notices u/s 143(2) & 142(1) of the Act were duly issued

Getinge Medical India Private Limited, Mumbai vs. DCIT 2(2)(1), Mumbai Maharashtra

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

ITA 4872/MUM/2024[2020-21]Status: DisposedITAT Mumbai13 Mar 2026AY 2020-21

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 115Section 115BSection 142(1)Section 143(2)Section 156Section 234ASection 270ASection 37Section 41Section 41(1)(a)

filed its return of income for assessment year under consideration declaring total income of Rs.26,79,29,490/-. Subsequently, the case was selected for complete scrutiny. Accordingly, notice u/s 143(2) of the Act was issued to assessee along with notice u/s 142(1) of the Act. In response

Vaneet Aggarwal, New Delhi vs. ACIT, Circle-14(2), New Delhi

In the result, appeal of the Assessee is dismissed

ITA 2607/DEL/2019[2015-16]Status: DisposedITAT Delhi13 Mar 2026AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 10(38)Section 143(1)Section 143(2)Section 69ASection 69C

same was processed u/s 143(1) of the Income Tax Act, 1961 (in short ‘the Act’). The case was selected for complete scrutiny through CASS. Notice u/s 143(2) and 142(1) of the Act were issued and served upon the assessee. 3. The assessee is a Director

Shri Durdundeshwar Urban Credit Souhard Sahakari Nyt, Belagavi vs. Income Tax Officer, Ward - 1, Gokak

Appeals are allowed for statistical purposes

ITA 311/PAN/2025[2017-18]Status: DisposedITAT Panaji12 Mar 2026AY 2017-18

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita No. 306 To 307 & 311/Pan/2025 Assessment Year : 2017-18 & 2020-21 Shri Durdundeshwar Urban Credit Souhard Sahakari Niyamita Subhash Road, Sankeshwar Belagavi-591313 Pan:Aaaas5612D . . . . . . . Appellant

For Appellant: NoneFor Respondent: Ms Rijula Uniyal [‘Ld. DR’]

Section 143(3)Section 246ASection 250Section 270ASection 80PSection 80P(2)

filed on 08/12/2020 declaring an income of ₹Nil after claiming deduction u/s 80P of the Act of ₹94,82,295/- was also selected for complete scrutiny & consequential assessment therefore was completed u/s 143(3) of the Act whereby total income of the assessee owning to similar denial of deduction ITAT

Shri Durdundeshwar Urban Credit Souhard Sahakari Nyt, Belagavi vs. Income Tax Officer, Ward - 1, Gokak

Appeals are allowed for statistical purposes

ITA 307/PAN/2025[2020-21]Status: DisposedITAT Panaji12 Mar 2026AY 2020-21

For Appellant: NoneFor Respondent: Ms Rijula Uniyal [‘Ld. DR’]

Section 143(3)Section 246ASection 250Section 270ASection 80PSection 80P(2)

Shri Durdundeshwar Urban Credit Souhard Sahakari Nyt, Belagavi vs. Income Tax Officer, Ward -1, Gokak

Appeals are allowed for statistical purposes

ITA 306/PAN/2025[2020-21]Status: DisposedITAT Panaji12 Mar 2026AY 2020-21

For Appellant: NoneFor Respondent: Ms Rijula Uniyal [‘Ld. DR’]

Section 143(3)Section 246ASection 250Section 270ASection 80PSection 80P(2)

Ajitbhai Bhimabhai Bharwad, Ahmedabad vs. The ITO, Ward-3(1)(1), Ahmedabad

The appeal of the assessee is allowed for statistical purposes

ITA 2609/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2022-23

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Tej Shah, A.RFor Respondent: Shri C Dharani Nath, Sr. DR

Section 271ASection 68Section 69Section 69A

assessee, an individual, filed the return of income for Assessment Year 2022-23 declaring total income of ₹16,250/-. The case was selected for complete scrutiny under CASS on Ajitbhai Bhimabhai Bharwad vs. ITO Asst. Year –2022-23 - 2– the issues of huge cash deposits and purchase and sale

Rajesh Pananalal Shah, Vadodara vs. Asstt. Unit, Juris. AO- Dy.CIT, Circle-1(1)(1), Vadodara

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

ITA 2581/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2022-23

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri C Dharani Nath, Sr. DRFor Respondent: Shri C Dharani Nath, Sr. DR

Section 115BSection 142(1)Section 143(2)Section 144Section 250Section 271ASection 68

filed the return of income for Assessment Year 2022-23 on 20.10.2022 declaring total income of ₹28,82,250/-. The case was selected for complete scrutiny under CASS on the issues of low income reported in comparison to TCS receipts on scrap and high liabilities as compared to income/receipts. During

Viren Vallabhdas Dhakan, Rajkot vs. Assistant Commissioner of Income Tax, Circle -2(1), Rajkot

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

ITA 34/RJT/2025[2017-18]Status: DisposedITAT Rajkot11 Mar 2026AY 2017-18

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

For Appellant: Shri D. M. Rindani, Ld. A.RFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 115bSection 143(3)Section 234aSection 250Section 271ASection 271aSection 68

Rs.13,53,640/-. The return of income has been processed u/s. 143(1) of the I. T. Act, 1961. The case was selected for complete scrutiny on the issue “(1) Undisclosed income reported during demonetization, Page 3 of 9 Viren Vallabhidas Dhakan (2) Abnormal increase in cash deposits during demonetization

Claymine Microns LLP, Wankaner vs. Principal CIT 1, Rajkot

In the result, the appeal of the assessee in ITA No

ITA 216/RJT/2024[2018-19]Status: DisposedITAT Rajkot11 Mar 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं. / Ita No. 216/Rjt/2024 Assessment Year: (2018-19) (Physical Hearing) Claymine Microns Llp Vs. Pcit Survey No. 59 At Ratavirda, Nr. Capron Aayakar Bhawan, Race Course Ceramic Sartanpar Road, Wankaner, Ring Road, Rajkot, Gujarat - Gujarat - 363641 360001 Pan/Gir No.: Aamfc4286C (Assessee) (Respondent) िनधा"रती की ओर से/Assessee By : Shri Hardik Vora, Ar राज" की ओर से/Respondent By : Shri Sanjay Punglia, Cit. Dr सुनवाई की तारीख/Date Of Hearing : 16/02/2026 घोषणा की तारीख/Date Of Pronouncement : 11/03/2026

For Appellant: Shri Hardik Vora, ARFor Respondent: Shri Sanjay Punglia, CIT. DR

Section 143(3)Section 263Section 68

Revenue and evidences on record. We find that case of the assessee, under consideration was taken-up for the complete scrutiny through CASS mainly for the reason of verification of the fresh capital introduced during the year. We note that during the course of assessment proceedings, the assessing officer

Aman Thukral, Ludhiana vs. Income Tax Officer Ward 2(1), Ludhiana

Accordingly, Additional Ground No. 1 is allowed for statistical

ITA 886/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh11 Mar 2026AY 2021-22

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

For Appellant: Sh. Pankaj Bhalla, CAFor Respondent: Sh. Manav Mangal, CIT DR

Section 143(3)Section 144BSection 250(6)Section 69C

case are that the assessee filed his return of income declaring a total income of Rs. 38,81,100/-. The case was selected for complete scrutiny under CASS primarily on the issue of business purchases. During the course of assessment proceedings, the Assessing Officer issued notices under section ... Officer had carried out extensive verification during the course of assessment proceedings. It was submitted that the case of the assessee was selected for complete scrutiny under CASS specifically on the issue of “Business Purchases”. During the course of assessment proceedings, the assessee was repeatedly required to furnish confirmations, copies

Murad Khetani, Hyderabad vs. DCIT., Circle-10(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1376/HYD/2025[2016-17]Status: DisposedITAT Hyderabad11 Mar 2026AY 2016-17

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

Section 131Section 142(1)Section 68

assessee to substantiate his claim. However, it is noticed that, the ITR filed by the assessee for A.Y. 2014-15 was selected for complete scrutiny and assessment was completed on 14.12.2016 by DCIT, Circle 10(1), Hyderabad. The claim of the assessee that most of the loans were only brought

Rekantaa Developers Pvt Ltd, Delhi vs. DCIT, Central Circle- 3, Delhi

In the result, both the appeals filed by the assessee are dismissed

ITA 6286/DEL/2025[2016-17]Status: DisposedITAT Delhi11 Mar 2026AY 2016-17

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla

For Appellant: NoneFor Respondent: Shri Nitin Kumar Jaiman, Sr. DR

Section 143Section 143(3)Section 250Section 68

from the balance sheet submitted by the assessee that there was increase in unsecured loans, the scrutiny proceedings of the assessee was completed into complete scrutiny from limited scrutiny vide approval dated 27.07.2017 passed by the PCIT-04. The assessee received Rs.2 crores from M/s Virat Exports Pvt. Ltd. which

Rekantaa Developers Pvt Ltd, Delhi vs. DCIT, Central Circle- 3, New Delhi

In the result, both the appeals filed by the assessee are dismissed

ITA 6285/DEL/2025[2015-16]Status: DisposedITAT Delhi11 Mar 2026AY 2015-16

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla

For Appellant: NoneFor Respondent: Shri Nitin Kumar Jaiman, Sr. DR

Section 143Section 143(3)Section 250Section 68

Sanjay Kumar Yadav, Delhi vs. CIT Appeal, Delhi

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

ITA 5825/DEL/2025[2022-23]Status: DisposedITAT Delhi11 Mar 2026AY 2022-23

Bench: Ms. Madhumita Roy & Shri Naveen Chandraassessment Year : 2022-23 Sanjay Kumar Yadav, Vs. Assessment Unit, 7802, Arakshan Road, Income-Tax Department Swami Ram Tirth Nagar, Paharganj, New Delhi – 110 055. Pan: Aarpy8996L

For Appellant: Shri Sumit Kumar Goenka, CAFor Respondent: Shri Mahesh Kumar, CIT-DR

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

return of income for AY 2022-23 on 26th September, 2022 declaring the income at Rs.16,16,535/-. Upon selection of the case for complete scrutiny for genuineness of transactions uploaded through VRU, identity of the parties related with transactions and whether the assessee has shown correct income

Atul Kumar Garg, Ghaziabad vs. Ld. Assessing Officer, Faceless, Delhi

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

ITA 5470/DEL/2025[2022-23]Status: DisposedITAT Delhi11 Mar 2026AY 2022-23

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumaratul Kumar Garg, Ld. Assessing Officer, B K Kapur & Co., Faceless, Delhi. 17, Navyug Market, Vs. Ghaziabad, 201001 Uttar Pradesh. Pan-Akzpk4529K (Appellant) (Respondent) Assessee By None Department By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 20.01.2026 Date Of Pronouncement 11.03.2026 O R D E R Per Vimal Kumar, Jm: The Appeal Filed By The Assessee Is Against Order Dated 04.07.2025 Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Assessment Order Dated 13.02.2024 Of The Assessment Unit Passed U/S 144B R.W.S 14B Of The Act For Assessment Year 2022-23. 2. Brief Facts Of The Case Are That The Assessee Is Running The Wholesale & Retail Trade Of Ghee, Oil & Such Other Products Under The Sole Proprietorship Business Under The Trade Name (Sole Proprietorship) Of M/S Atul Trading Co. During The Year Atul Kumar Garg Vs. Assessing Officer

Section 142(1)Section 143(2)Section 144BSection 250Section 69C

filed return of income on 15.10.2022 declaring total income at Rs.18,10,940/-. Later on, the case of assessee was selected for complete scrutiny through CASS. The assesse has shown gross turnover at Rs.35,57,29,186/- on which gross profit was also shown at Rs.51,21,676/-. The assessee

Microtek Infrastrutures Private Limited, Delhi vs. PCIT, New Delhi

In the result, the appeal of the assessee is dismissed

ITA 3112/DEL/2025[2020-21]Status: DisposedITAT Delhi11 Mar 2026AY 2020-21

Bench: Shri Anubhav Sharma& Shri Amitabh Shukla[Assessment Year:2020-21]

Section 133(6)Section 142(1)Section 143(3)Section 263Section 37(1)Section 68

have noted that the assessment order is totally silent on the issue. In spite of the case being selected in the complete scrutiny category for intensive examination and Page 11 of 15 verification, there is nothing on record to suggest that any such exercise was undertaken

Pushpendra Singh, Raebareli vs. DCIT Circle, Faizabad

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

ITA 14/LKW/2024[2018-19]Status: DisposedITAT Lucknow10 Mar 2026AY 2018-19

Bench: Shri Kul Bharat & Shri Anadee Nath Misshraassessment Year: 2018-19 Pushpendra Singh V. Dcit Circle, 680, Amar Nagar, Raebareli Faizabad/National E- (U.P)-229001. Assessment Centre Delhi Pan:Axbps1905L (Appellant) (Respondent) Appellant By: Shri P. K. Kapoor, C.A. Respondent By: Shri R. R. N. Shukla, Addl. Cit(Dr) O R D E R

For Appellant: Shri P. K. Kapoor, C.AFor Respondent: Shri R. R. N. Shukla, Addl. CIT(DR)

Section 143(3)Section 144BSection 194CSection 40

assessing officer in examining the TDS details without obtaining necessary approval from the competent authority for converting the limited purpose scrutiny so complete scrutiny. 2.1. BECAUSE the "CIT(A)" has erred in law and on facts in confirming the addition of Rs. 19,18,769/- made by the Assessing Officer ... Limited Scrutiny to examine income from real estate business. However. as seen from the assessment order, it is specifically mentioned that a is a complete scrutiny as per assessment scheme 2019 and hence, there is no requirement of any approval of the competent authority. The approval is necessary only

Manish N. Amin, Ahmedabad vs. The ITO, Ward-3(3)(2), Ahmedabad

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

ITA 88/AHD/2026[2017-18]Status: DisposedITAT Ahmedabad10 Mar 2026AY 2017-18

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaassessment Years: 2017-18

Section 143(3)Section 250Section 69A

filed his return of income for A.Y. 2017-18 on 13.10.2017 declaring total income of Rs.5,37,900/-. The case was selected for complete scrutiny under CASS. In the course of assessment, the AO noticed that the assessee had made cash deposit of Rs.47,16,000/- in his bank account

Dilipkumar Sohanlal Maheshwari, Ahmedabad vs. The ACIT, Circle-1(1)(2), Ahmedabad

The appeal of the assessee is dismissed

ITA 1662/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad10 Mar 2026AY 2017-18

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2017-18

For Appellant: Shri Kalpesh Shah, A.RFor Respondent: Shri Abhijit, Sr. D.R

Section 10(35)Section 10(38)Section 115BSection 142Section 143Section 143(2)Section 68

assessee filed return of income on 23-09-2017 declaring total income at Rs. 74,89,690/-. The case was selected for complete scrutiny and notice u/s. 143(2) of the Income Tax Act dated 22-09-2018 was issued and served upon the assessee. The statutory notices were issued