“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

Ammapalayam Basuvaptti Primary Agricultural Co Op Credit Society Limited, Erode vs. The Income Tax Officer, Ward 2(1) Erode, Erode

In the result, the appeal of the assessee is allowed

ITA 2706/CHNY/2025[2020-21]Status: DisposedITAT Chennai04 Dec 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Ms.A. Vijayalakshmi, CAFor Respondent: Mr.R. Raghupathy, Addl.CIT

Section 270ASection 56Section 80PSection 80P(2)(a)

Brief facts are that the assessee is a Primary Agricultural Cooperative Credit Society (hereinafter referred to as ‘PACCS‘), whose ITR was selected for complete scrutiny; and the AO is noted to have inter- alia disallowed the claim of deduction u/s.80P of the Act to the tune

Ammapalayam Basuvaptti Primary Agricultural Co Op Credit Society Limited, Erode vs. The Income Tax Officer, Ward 2(1) Erode, Erode

In the result, the appeal of the assessee is allowed

ITA 2705/CHNY/2025[2020-21]Status: DisposedITAT Chennai04 Dec 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Ms.A. Vijayalakshmi, CAFor Respondent: Mr.R. Raghupathy, Addl.CIT

Section 270ASection 56Section 80PSection 80P(2)(a)

Chhatrapati Nagri Sahkari Patsanstha M, Beed vs. ITO, Ward-1, Jalna

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

ITA 1804/PUN/2025[2017-18]Status: DisposedITAT Pune03 Dec 2025AY 2017-18

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: NoneFor Respondent: Shri Bharat Andhale, Addl.CIT

Section 143(3)Section 250Section 250(6)Section 37Section 68Section 80P

society and return of income for A.Y. 2017-18 filed on 31/03/2018 declaring loss of Rs. 1,96,348/-. After the case selected for complete scrutiny under CASS, valid statutory notices were served and assessment proceedings were carried out. Ld.AO, on due consideration of the submissions filed by the assessee

Aum Citiscapes LLP, Pune vs. The ITO Ward 7(1), Pune

In the result, appeal of the Assessee is allowed

ITA 1160/PUN/2025[2018-19]Status: DisposedITAT Pune03 Dec 2025AY 2018-19

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Ms. Abhilasha S. Kakani, CAFor Respondent: Shri Bharat Andhale, Addl.CIT

Section 143(3)Section 250Section 68

limited liability partnership and NIL income declared in the return of income for A.Y. 2018-19 furnished on 08/08/2018. Case selected for complete scrutiny on two issues, namely „income from real estate business‟ and „unsecured loans‟. Various details were called for, to which, partial reply was made. Ld.AO concluded

Bhavana Co-Op Credit Society Niyamita, Sirsi vs. Income Tax Officer, Ward-1, Sirsi

In the result the appeal filed by the assessee is allowed

ITA 1074/BANG/2025[2020-21]Status: DisposedITAT Bangalore03 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

For Appellant: Sri V. Srinivasan, A.RFor Respondent: Sri Shivanand H Kalakeri, D.R

Section 142(1)Section 143(2)Section 143(3)Section 263Section 80P(2)(a)Section 80P(2)(i)

amounting to Rs. 55,74,646/-. The case of the assessee society was thereafter selected for complete scrutiny through CASS to examine the following issues:- i) High liabilities as compared to low income/receipts. ii) Low income (including exempt income and agricultural income) in comparison to high loans/advances/investment in shares appearing ... documentary evidence/ written submission/ explanation etc. did not draw any adverse inference in respect of the issues for which the case was selected for complete Scrutiny. Further, the AO categorically observed that the issue was explained by the assessee and submission was found in order regarding the issues and accordingly

Gonikoppal Primary Rural Agricultural Credit Co-Operative Society Limited, Kodagu vs. Pr. Commissioner of Income Tax, Bengaluru-3, Bengaluru

In the result the appeal filed by the assessee is allowed

ITA 1072/BANG/2025[2020-21]Status: DisposedITAT Bangalore03 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

For Appellant: Sri V. Srinivasan, A.RFor Respondent: Sri Shivanand H Kalakeri, D.R

Section 142(1)Section 143(2)Section 143(3)Section 263Section 80P(2)(a)Section 80P(2)(i)

DCIT Central Circle-1, Noida vs. Nivedan Fin-Invest Lease Ltd., Delhi

In the result, Revenue’s appeal is dismissed

ITA 1713/DEL/2023[2015-16]Status: DisposedITAT Delhi03 Dec 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandraassessment Year: 2015-16

Section 115BSection 133(6)Section 147Section 148Section 151Section 69A

that for A.Y. 2015-16 the assessee filed its original return declaring income of Rs. 78,80,197/-. The case was selected for complete scrutiny under CASS and the assessment was completed at Rs 83,04,340/-. Subsequently, on receipt of information from Investigation Wing, Noida that the assessee company ... main source of its income during the year is interest. Ld AR submits that the original assessment proceedings were undertaken as per CASS for complete scrutiny by issuing statutory notices u/s 143(2) of the Income Tax Act and all the details as sought by the Ld AO for carrying

Shankar, Patna vs. Income Tax Officer Ward- 6 (1), Patna

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

ITA 159/PAT/2025[2017-18]Status: DisposedITAT Patna02 Dec 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(2)Section 250

return of income for the assessment year 2017-18 on 31.03.2018 showing total income of Rs.3,04,120/-. The case was selected for complete scrutiny through Computer Assisted Scrutiny Selection (CASS). Accordingly notice under section 143(2) was generated on 21.09.2018 and was served through mail upon the assessee, requiring

Hindcon Chemicals Limited, Kolkata vs. D.C.I.T., Circle - 11(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1807/KOL/2025[2014-2015]Status: DisposedITAT Kolkata02 Dec 2025AY 2014-2015

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Dcit, Circle 11(1) Hindcon Chemicals Limited Aaykar Bhawan Poorva, P-7, 62B, Braunfeld Row, 1 St Floor Chowringhee Square, Vs. Kolkata-700027, West Bengal Kolkata-700069, West Bengal (Appellant) (Respondent) Pan No. Aaach8021M Assessee By : Shri A.K. Tirbriwal, Ar Revenue By : Shri Subrata Aich, Dr Date Of Hearing: 10.11.2025 Date Of Pronouncement: 02.12.2025

For Appellant: Shri A.K. Tirbriwal, ARFor Respondent: Shri Subrata Aich, DR

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

vehemently submitted that the notice u/s 143(2) of the Act, does not specify whether it is a limited scrutiny or a complete scrutiny or a compulsory manual scrutiny. The ld. AR submitted that the CBDT has issued specific instruction vide instruction no. F. No. 225/157/2017/ITA-II Dated ... other hand submitted that this is a computer- generated notice and the non-mentioning of the fact of either limited or complete scrutiny or compulsory manual scrutiny would not render the issuance of notice u/s 143(2) of the Act as invalid. Therefore, additional ground raised by the assessee

Madras Diocesan Council Employees Provident Fund, Chennai vs. ITO, Non Corporate Circle-3(1), Chennai

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

ITA 2497/CHNY/2025[2018-19]Status: DisposedITAT Chennai02 Dec 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Ms. Gouthami Manivasagam, J.C.I.TFor Respondent: 18.11.2025

Section 10(25)(ii)Section 143(1)Section 144

arriving at a total income of Rs.72,14,830/- raising refund of Rs.10,38,345/-. The case was selected for ‘Complete Scrutiny’ under CASS to verify Form 10B filing compliance and statutory notices were issued to the assessee to furnish the trust deed and state in detail the nature

Iqvia Ag, Switzerland vs. The Deputy Commissioner of Income Tax (Internaltional Taxation) - 2(2)(2), Mumbai

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

ITA 4549/MUM/2023[2021-22]Status: DisposedITAT Mumbai02 Dec 2025AY 2021-22

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhan

Section 142(1)Section 143(2)Section 144C(5)Section 90(2)

return of income for A.Y 2020-21 on 13.02.2021 declaring total income of Rs. 58,87,36,450/-. The case was selected for complete scrutiny under CASS and notice u/s. 143(2) of the Act dated 29.06.2021 was issued and duly served on the assessee. Thereafter notices

Iqvia Ag, Switzerland vs. The Income Tax Officer (International Taxation) - 2(2)(1), Mumbai

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

ITA 3359/MUM/2023[2020-21]Status: DisposedITAT Mumbai02 Dec 2025AY 2020-21

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhan

Section 142(1)Section 143(2)Section 144C(5)Section 90(2)

Mawasi, Haryana vs. Commissioner of Income Tax (Appeals), Delhi

In the result, appeal of the assessee is allowed

ITA 5020/DEL/2025[2017-18]Status: DisposedITAT Delhi02 Dec 2025AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: NoneFor Respondent: Ms. Amisha S. Gupta, CIT-DR

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

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

Balaji Powertronics, New Delhi vs. DCIT, Circle- 43(1), New Delhi

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

ITA 2743/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Dec 2025AY 2017-18

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2017-18 M/S. Balaji Powertronics, Vs. Dcit, Circle-43(1), H-56, Udyog Nagar, New Delhi Main Rohtak Road, Delhi – 1100 41 Pan :Aagfb0501M (Appellant) (Respondent)

Section 142(1)Section 143(2)Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 270ASection 80Section 928A

filed its return of income on 27-11-2017 declaring total income was declared at Rs.26,09,71,590/-. The case was taken under complete scrutiny. Notices under Section 143(2) dated 17-08- 2018 and 27-09-2018 were issued. Notices under Section 142(1) of the Act with

Shardaben Dhanjibhai Savani, Surat vs. ITO, Ward 2(3)(4), Surat

In the result, the ground of appeal raised in this appeal is

ITA 387/SRT/2025[2021-22]Status: DisposedITAT Surat28 Nov 2025AY 2021-22

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusetharr Atta H./Ita Nos. 385 To 387/Srt/2025 (Ay 2021-22) (Physical Hearing) Shardaben Dhanjibihai Savani Assessment Unit Income-Tax 74-75, 3" Floor Om Industries-8, Department Jurisdictional Ao/ Umbhel Road, Parabgam, Kamrej, Ary Income Tax Officer, Surat-394 101 Vs Ward-2(3)(4) Surat, Aaykar [Pan : Kiyps 3244 C] Bhawan, Majura Gate, Surat- 395 001 Ardenelf/ Appellant Weet Respondent Prafftdt #1 Sik A /Assessee By Shri P.M. Jagasheth, Ca Weed Sg Six S /Revenue By Shri Ajay Uke, Sr-Dr | Aare Wt Artg/Date Of Hearing 15.09.2025 Suit Ht Arg/Date Of Pronouncement | 28.11.2025

Section 144Section 250Section 254(1)Section 271A(1)(d)

case is the assessee filed her return of income declaring total income of Rs.4,82,080/- on 16.12.2021. Subsequently, case was selected for complete scrutiny under CASS because of large import and export and the return filed by assessee is non-business income. Several notices issued

Shardaben Dhanjibhai Savani, Surat vs. ITO, Ward 2(3)(4), Surat

In the result, the ground of appeal raised in this appeal is

ITA 386/SRT/2025[2021-22]Status: DisposedITAT Surat28 Nov 2025AY 2021-22

Section 144Section 250Section 254(1)Section 271A(1)(d)

Shardaben Dhanjibhai Savani, Surat vs. ITO, Ward 2(3)(4), Surat

In the result, the ground of appeal raised in this appeal is allowed for statistical purposes

ITA 385/SRT/2025[2021-22]Status: DisposedITAT Surat28 Nov 2025AY 2021-22

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos. 385 To 387/Srt/2025 (Ay 2021-22) (Physical Hearing) Shardaben Dhanjibihai Savani Assessment Unit Income-Tax 74-75, 3Rd Floor Om Industries-8, Department Jurisdictional Ao/ Umbhel Road, Parabgam, Kamrej, Income Tax Officer, बनाम/ Surat-394 101 Ward-2(3)(4) Surat, Aaykar Vs [Pan : Kiyps 3244 C] Bhawan, Majura Gate, Surat- 395 001 अपीलाथ"/Appellant ""थ" /Respondent

Section 144Section 250Section 254(1)Section 271A(1)(d)

Aahana Sales Private Limited, Ahmedabad vs. PCIT(Central), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 878/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad28 Nov 2025AY 2018-19

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2018-19 Aahana Sales Private Limited Pr.Cit(Central) 3, Bhavya Enclave Vs. Ahmedabad. Vidhya Vihar Society Usmanpura Ahmedabad. Pan : Aajca 1231 B (Applicant) (Responent) Assessee By : Shri Vivek Chavda, Ar Revenue By : Shri R.P. Rastogi, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 11/11/2025 घोषणा क" तारीख /Date Of Pronouncement: 28 /11/2025 आदेश/O R D E R Per Makarand V.Mahadeokar, Am:

For Appellant: Shri Vivek Chavda, ARFor Respondent: Shri R.P. Rastogi, CIT-DR

Section 143(1)Section 144Section 147Section 148Section 263Section 263(1)

Officer had failed to discharge his duty of enquiry. The Principal Commissioner further held that reassessment under section 147 partakes the character of a complete scrutiny and that the Assessing Officer was empowered to examine all issues arising from the assessment records, irrespective of the reasons recorded. Relying upon Explanation ... evidences submitted by the appellant during the assessment proceedings. 4 2.1 The Ld. PCIT has erred in law in holding that reassessment proceedings are complete scrutiny proceedings allowing examination of any issue, when the law clearly states that reassessment must be confined to the issues for which reasons were recorded

The Satara Zilla Krishi Bank Karmachari Sahakari Patsanstha Ltd, Satara vs. ACIT, Satara, Cir-Satara

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

ITA 2156/PUN/2025[2020-21]Status: DisposedITAT Pune28 Nov 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.2155 & 2156/Pun/2025 निर्धारण वर्ष / Assessment Year : 2020-21 The Satara Zilla Krishi Bank Karmachari Sahakari Patsanstha Ltd., Ajinkya Complex, 512, Ch. Shivaji Road, Camp, Sadar Bazar, Satara-415001 Asst. Commissioner Of Income Tax, Satara Circle, Vs. Satara Pan: Aaaat1502B अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Ms. Renuka Arunrao Ghatge Shri S. Sadananda Singh 11-11-2025 28-11-2025 आदेश / Order Per Astha Chandra, Jm : The Above Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Both Dated 15.07.2025 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)”/“Nfac"] Pertaining To Assessment Year (“Ay") 2020-21. For The Sake Of Convenience, Both These Appeals Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Department byFor Respondent: Date of hearing

Section 139(1)Section 143(2)Section 144Section 41(1)Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(b)Section 80P(2)(d)

income of Rs.2,47,680/- u/s 139(1) of the Income Tax Act, 1961 (the "Act"). The case of the assessee was selected for complete scrutiny under the E-assessment Scheme, 2019 on the issue of Deduction from total income under VI-A and High liabilities as compared

The Satara Zilla Krishi Bank Karmachari Sahakari Patsanstha Ltd, Satara vs. ACIT, Satara, Cir-Satara

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

ITA 2155/PUN/2025[2020-21]Status: DisposedITAT Pune28 Nov 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.2155 & 2156/Pun/2025 निर्धारण वर्ष / Assessment Year : 2020-21 The Satara Zilla Krishi Bank Karmachari Sahakari Patsanstha Ltd., Ajinkya Complex, 512, Ch. Shivaji Road, Camp, Sadar Bazar, Satara-415001 Pan: Aaaat1502B अपीलार्थी / Appellant Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Asst. Commissioner Of Income Tax, Satara Circle, Vs. Satara प्रत्यर्थी / Respondent Ms. Renuka Arunrao Ghatge Shri S. Sadananda Singh 11-11-2025 28-11-2025 आदेश / Order Per Astha Chandra, Jm : The Above Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Both Dated 15.07.2025 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)”/“Nfac"] Pertaining To Assessment Year (“Ay") 2020-21. For The Sake Of Convenience, Both These Appeals Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Department byFor Respondent: Date of hearing

Section 139(1)Section 143(2)Section 144Section 41(1)Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(b)Section 80P(2)(d)

income of Rs.2,47,680/- u/s 139(1) of the Income Tax Act, 1961 (the “Act”). The case of the assessee was selected for complete scrutiny under the E-assessment Scheme, 2019 on the issue of Deduction from total income under VI-A and High liabilities as compared