“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

Ubs Business Solutions (India) Private Limited (Successor to Credit Suisse Services (India) Pvt Ltd), Pune vs. PCIT, Pune - 1, Pune, Maharashtra

In the result, appeal of the Assessee is allowed

ITA 1407/PUN/2025[2020-21]Status: DisposedITAT Pune28 Nov 2025AY 2020-21

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1407/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Ubs Business Solutions (India) V The Principal Pvt. Ltd. (Successor To Credit S. Commissioner Of Suisse Services (India) Pvt Income Tax, Ltd.), Pune-1. Cluster A, Eon Free Zone, Plot No.1, S.No.77, Ground To 5Th Floors In Wing 1, 3Rd To 5Th Floor In Wing 2, Kharadi Midc Knowledge Park, Pune – 411014. Pan: Aabcu8718M Appellant/ Assessee Respondent / Revenue Assessee By Shri Rajendra Agiwal - Ar Revenue By Shri Amit Bobde – Cit(Dr) Date Of Hearing 23/09/2025 Date Of Pronouncement 28/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Principal Commissioner Of Income Tax, Pune-1 Passed Under Section 263 Of The Income Tax Act, 1961 For A.Y.2020-21, Dated 31.03.2025 Emanating From Assessment Order U/S.143(3) R.W.S 144B

Section 143(3)Section 144BSection 263Section 80G

refund out of self-assessment tax. The learned Assessing Officer ('Ld. AO') has not only examined the above issues but has also conducted complete scrutiny vis-a-vis these points. (b)In view of the above, the impugned assessment order cannot be held as erroneous and prejudicial for alleging lack ... income is enclosed on page no. 87 to 90 of the factual paper book submitted on 02.07.2025). The appellant's case was selected for complete scrutiny under Faceless Assessment Scheme through CASS (Please refer notice U/s 143(2) dated 29.06.2021 on page no. 392 of the Paper book). The case

Agarwal Holdings Private Limited, Mumbai vs. Principal Commissioner of Income Tax -1, Mumbai

In the result, the appeal by the assessee is dismissed

ITA 3389/MUM/2025[2022-23]Status: DisposedITAT Mumbai28 Nov 2025AY 2022-23

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalagarwal Holdings Private Ltd. 211, 2Nd Floor Atlanta Arcade, Marol Church Road Marol, Andheri (East) Mumbai - 400059 ............... Appellant Pan: Aauca5094K V/S Principal Commissioner Of Income Tax, Mumbai-1 ……………… Respondent Room No.330, 3Rd Floor, Aayakar Bhavan, Maharishi Karve Road, Mumbai Assessee By : Shri Ashok Bansal Revenue By : Shri Rajesh Kumar Yadav, Cit-Dr

For Appellant: Shri Ashok BansalFor Respondent: Shri Rajesh Kumar Yadav, CIT-DR

Section 111ASection 142(1)Section 143(3)Section 144BSection 263

invested in equity shares, mutual funds, bonds and liquid funds. For the year under consideration, the return filed by the assessee was selected for complete scrutiny for the following reasons through CASS and statutory notices under 3 section 143(3) and section 142(1) of the Act were issued ... gains/losses to tax under the head “capital gain”. We find that during the scrutiny proceedings, the return filed by the assessee was selected for complete scrutiny, inter alia, for the reason “large short-term capital gains declared under section 111A”. Vide notice dated 20.01.2024 issued under section

Raj Singh, Delhi vs. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre Delhi

In the result, appeal of the assessee is allowed

ITA 6710/DEL/2025[2020-2021]Status: DisposedITAT Delhi28 Nov 2025AY 2020-2021

Bench: Shri Satbeer Singh Godaraassessment Year: 2020-21

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

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

Rajpal, Jhajjar vs. Income Tax Officer, National Faceless Assessment Unit

In the result, appeal of the assessee is allowed

ITA 6697/DEL/2025[2020-2021]Status: DisposedITAT Delhi28 Nov 2025AY 2020-2021

Bench: Shri Satbeer Singh Godaraassessment Year: 2020-21

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

Veer Projects, Raipur vs. Dy. Commissioner of Income Tax, Circle 1(1), Raipur

ITA 654/RPR/2025[2018-19]Status: DisposedITAT Raipur27 Nov 2025AY 2018-19

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 654/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19)

For Appellant: Shri Vikram Chhabda, C.AFor Respondent: Shri Saad Kidwai, CIT-DR

Section 115BSection 143(3)Section 249(2)Section 250Section 68

return for AY 2018-19 on 31.10.2018, declaring total income of Rs. 51,29,960/-, thereafter its case has been selected for complete scrutiny under “CASS”. Statutory notices were issued, queries raised, which was responded by the assessee and the assessment was completed with following additions: 3 Veer Projects

Rose Bud Muslim Educational Society, Patna vs. ITO, Exemption, Ward-1, Patna

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

ITA 40/PAT/2025[2016-17]Status: DisposedITAT Patna27 Nov 2025AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 12Section 12ASection 142(1)Section 144Section 250

assessment year under consideration. The assessee had filed the return of income showing total income at ₹NIL. The return was selected for complete scrutiny under Computer Assisted Scrutiny Selection (CASS) and statutory notices were issued, which were not complied with nor any document/bill & voucher/paper as requisitioned vide different notices issued

Gram Nirman Mandal, Nawada vs. Dc/Ac Exemption, Cir, Patna

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

ITA 336/PAT/2025[2018-19]Status: DisposedITAT Patna27 Nov 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 10Section 11Section 143(3)Section 250

Artificial Juridical Person, which filed its return of income on 29.10.2018 for the AY 2018- 19 declaring ₹NIL income. The case was selected for complete scrutiny assessment under the e-Assessment Scheme, 2019 on the issue of business income of Trust. Statutory notices were issued to the assessee. The assessee

Income Tax Officer, New Libra Kothi, Railway Road, Sirhind vs. Bhagwan Dass, Amloh Road, Mandi Gobindgarh

In the result, appeal of the Revenue is dismissed

ITA 1025/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh27 Nov 2025AY 2021-22

For Respondent: Shri Tej Mohan Singh, Advocate

Section 115BSection 133(6)Section 143(1)Section 36(1)Section 36(1)(vii)Section 68

total income of Rs.11,05,810/-. The return was processed under section 143(1) of the Act. Subsequently, the case was selected for complete scrutiny under CASS, for complete scrutiny with the reason “Assessee has made substantial purchases from such suppliers who are either Non-Filer(s) or have filed

Vinodkumar Bhaleram Lamba, Vadodara vs. ITO Ward-1(2)(2), Vadodara

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

ITA 1474/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad27 Nov 2025AY 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal & (Assessment Year: 2020-21)

For Appellant: Shri A.K Khandelwal, ARFor Respondent: Shri C Dharani Nath, Sr. DR

Section 143(2)Section 80C

year under consideration was filed on 20.01.2021, declaring a current year business loss of Rs. 2,61,463/-. The case was selected for complete scrutiny, and a notice under section 143(2) of the Act was issued on 29.06.2021, specifically to examine the issue of “Income from toll plaza.” During

Shri Vir Transport Opertors Copo Credit & Service Society Ltd., Dahod vs. The Dy. CIT, Anand Circle, Ahmedabad

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

ITA 1465/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad27 Nov 2025AY 2020-21

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokar

For Appellant: Ms. Ursvashi Sodhan, ARFor Respondent: Shri Girish Parihar, Sr. DR

Section 143(1)(a)Section 143(2)Section 143(3)Section 144BSection 270ASection 56Section 57Section 80PSection 80P(2)(d)

under section 80P of the Act. The return was processed under section 143(1)(a) on 25.11.2021. The case was selected for Complete Scrutiny under CASS. Notices were issued under section 143(2) and 142(1) along with questionnaires were issued. 3. During the course of assessment proceedings, the Assessing