← All Phrases

“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

Ahmednagar Zilla Gramsevakanchi Sahakar Patsanstha Maryadit, Ahilyanagar vs. PCIT, Pune-1, Pune

In the result, the appeal of the assessee is allowed

ITA 1301/PUN/2025[2020-21]Status: DisposedITAT Pune25 Nov 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1301/Pun/2025 निर्धारण वर्ष / Assessment Year : 2020-21 Ahmednagar Zilla Gramsevakanchi Sahakari Patsanstha Maryadit, 1, Opp. Sardar Patel Karyala, Behind Vs. Ketkar Hospital, Ahilyanagar-414001 The Pr. Cit, Pune-1 Pan : Aaaaa6582G अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Shri Prasad S Bhandari Shri Amol Khairnar 11-09-2025 25-11-2025 आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 22.03.2025 Of The Ld. Principal Commissioner Of Income Tax, Pune-1 (“Pcit)” Passed U/S 263 Of The Income Tax Act, 1961 (The “Act”) Pertaining To Assessment Year (“Ay”) 2020-21. 2. The Assessee Has Raised The Following Grounds Of Appeal : “1. On The Facts & In The Prevailing Circumstances Of The Case, Respected Pcit Pune -1 Erred Passing The Impugned Revision Order Under Section 263 Without Appreciating The Fact That Interest On The Deposits Made By A Co-Operative Society With The Co-For Operative Bank Is Eligible Deduction Under Section 80P Of The Act. Hence, The Impugned Order Under Section 263 May Please Be Squashed. 2. On The Facts & In The Prevailing Circumstances Of The Case, Respected Pcit Pune 1 Erred Passing The Impugned Revision Order Under Section 263 Without Appreciating The Submission Made By The Assessee Society & The Judgments Of Hon'Ble Jurisdictional Pune

For Appellant: Department byFor Respondent: Date of hearing
Section 143(2)Section 143(3)Section 263Section 56Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

preparing the return of income, there are certain issues, on which further clarification is required, therefore, return of income has been selected for complete scrutiny. किन मुद्दों पर प्रारम्भ में और स्पष्टीकरण की आवश्यकता है? What is/are the Issue(s) on which further clarification is required initially? S No Issue ... Income under Chapter VI-A चूंकि यह सम्पूर्ण संवीक्षा है, निर्धारण प्रक्रिया के दौरान और प्रश्न किए जा सकते हैं। Since it is a complete scrutiny, further queries may arise during the course of assessment proceedings. आपको क्या करने की आवश्यकता है? What you need to do? आप ई-फाइलिंग

Income Tax Officer, Ward-1(3), Ludhiana vs. Shree Balaji Processors, Ludhiana

The appeal stands dismissed

ITA 797/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh24 Nov 2025AY 2016-17

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No. 797/Chandi/2023 (िनधा"रण वष" / Assessment Year: 2016-17) Ito Ward 1(3) Shree Balaji Processors बनाम/ Ludhiana – 141001 Tajpur Road, Opp. Central Jail Vs. Ludhiana - 141010 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Actfs-8428-B (अपीलाथ"/Appellant) (""थ" / Respondent) : Assessee By : Shri Sudhir Sehgal (Advocate) - Ld. Ar Revenue By : Shri Bharat Bhushan Garg (Cit) – Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 11-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 24/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Revenue For Assessment Year (Ay) 2016-17 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac, Delhi [Cit(A)] Dated 18-10-2023 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) Of The Act On 23-12-2018 Rejecting Books Of The Assessee & Assessing Business Profit Of Rs.12.81 Crores. The Ld. Cit(A) Reversed The Action Of Ld. Ao Against Which The Revenue Is In Further Appeal Before Us With Following Grounds Of Appeal: - 1. That The Cit(A), Ludhiana Has Erred In Law, In Deleting Addition Of Rs.12,01,85,191/- Made By The Assessing Officer On Account Of Rejecting The Books Of Accounts U/S 145(3) Of The Act.

For Appellant: Shri Sudhir Sehgal (Advocate) - Ld. ARFor Respondent: Shri Bharat Bhushan Garg (CIT) – Ld. DR (Virtual)
Section 142(1)Section 143(3)Section 145(3)

records, the appeal is disposed-off as under. Proceedings before lower authorities 2. The assessee declared income of Rs.79.85 Lacs which was subjected to complete scrutiny. The hearing notices were issued by Ld. AO u/s 142(1) from time to time which were responded to by the assessee along with

Birlasoft Limited, Pune vs. DCIT, Circle 8, Pune

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

ITA 1116/PUN/2023[2018-19]Status: DisposedITAT Pune24 Nov 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Birlasoft Limited Dcit, Circle – 8, Pune 35 & 36, Rajiv Gandhi Infotech Vs. Park, Phase-1, Midc, Hinjawadi, Pune – 411057 Pan: Aaack7308N (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 30-09-2025 Date Of Pronouncement : 24-11-2025 O R D E R Per R.K. Panda, V.P: This Appeal Filed By The Assessee Is Directed Against The Order Dated 23.08.2023 Of The Ld. Cit(A) / Nfac, Delhi Relating To Assessment Year 2018-19. 2. Facts Of The Case, In Brief, Are That The Assesse Is A Public Limited Company & Is Engaged In The Business Of Computer & Software Services. It Filed Its Return Of Income On 29.11.2018 Declaring Total Income Of Rs.95,13,15,400/-. The Return Was Processed By The Cpc & An Intimation U/S 143(1) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Was Passed On 25.01.2021 Determining The Total Income At Rs.1,00,23,03,750/-. The Case Was Selected For Complete Scrutiny Assessment Under The E-Assessment Scheme, 2019 On The Following Issues:

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10ASection 10A(3)Section 143(1)Section 143(2)Section 27Section 36(1)(va)Section 51Section 80ISection 90

referred to as ‘the Act’) was passed on 25.01.2021 determining the total income at Rs.1,00,23,03,750/-. The case was selected for complete scrutiny assessment under the E-assessment Scheme, 2019 on the following issues: 2 S. No. Issues i. Claim of Any Other Amount Allowable as Deduction

Suresh Kumar Somani, Malkangiri vs. Assistant Commissioner of Income Tax, Berhampur

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

ITA 55/CTK/2025[2017-18]Status: DisposedITAT Cuttack21 Nov 2025AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vice- & Shri Rajesh Kumarita No.55 /Ctk/2025 Assessment Year: 2017-18 Suresh Kumar Somani…………………………………................……….……Appellant Motu Road, Korukonda B.O, Alur, Malkangiri (Odisha), Odissa - 764045.. [Pan: Acxps8005Q] Vs. Acit, Berhampur………....………..…………………………...……...…..…..Respondent Appearances By: Shri R. B. Doshi, Ar, Appeared On Behalf Of The Appellant. Shri Vijay Singh, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 19, 2025 Date Of Pronouncing The Order : November 21, 2025 Order Per Rajesh Kumar: This Appeal Filed By The Assessee Is Directed Against The Order Dated 22.03.2024 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2017–18. 2. The Appeal Has Been Filed By The Assessee With A Delay Of 228 Days. The Assessee Has Filed An Affidavit For Condonation Of The Delay. After Considering The Reasons Cited In The Affidavit For Condonation Of Delay, We Find That The Reasons Are Valid & Consequently, The Delay In Filing The Appeal Is Hereby Condoned & We Proceed To Dispose Of The Appeal On Merits.

Section 143(2)Section 250Section 40A(3)

return of income for the assessment year under consideration declaring total income of Rs.16,09,480/-. The case of the assessee was selected for complete scrutiny through CASS and notice u/s 143(2) of the Act was issued but there was no compliance from the assessee. During the assessment proceedings

Ch Veerraju Co, Rajahmundry vs. DCIT, Circle-1, Rajahmundry

The appeal of the assessee is partly allowed in terms of our aforesaid observations

ITA 561/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam21 Nov 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.561/Viz/2025 (निर्धारण वर्ा/Assessment Year: 2018-19) Ch. Veerraju & Co, Vs. Deputy Commissioner Of Rajahmundry. Income Tax, Pan: Aacfc8959Q Circle-1, Rajahmundry. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Smt. A. Aruna, Advocate रधजस्‍व द्वधरध/Revenue By: Dr. Aparna Villuri, Sr. Ar सुिवधई की तधरीख/Date Of 18/11/2025 Hearing: घोर्णध की तधरीख/Date Of 21/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee Firm Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 26/08/2025 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 143(3) R.W.S143(3A) & 143(3B) Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 15/04/2021 For The Assessment Year 2018-19. The 2 Ch Veerraju & Co Vs. Dcit

For Appellant: Smt. A. Aruna, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(3)

27/09/2018, declaring an income of Rs. 2,06,10,750/-. Subsequently, the case of the assessee firm was selected for complete scrutiny for verifying whether the addition in an earlier AY was confirmed in appeal or has become final on recurring issue of law or fact. 3. During the course