“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

Jitendrasinh Zala, Jamnagar vs. The Pr.Commissioner of Income Tax, Jamnagar

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

ITA 871/RJT/2024[2020-21]Status: DisposedITAT Rajkot18 Nov 2025AY 2020-21

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

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)

Section 143(3)Section 263

03/02/2021, declaring total income at Rs. 15,85,390/-. Thereafter, the case of the assessee for the assessment year under consideration was selected for complete scrutiny assessment. Accordingly, the assessment was finalized u/s 143(3) r.w.s. 144B of the Income-tax Act (for short 'the Act') dated 06/09/2022, accepting ... deducted out of various expenses incurred. ITA 871/Rjt/24 AY. 2020-21 JITENDRASINH ZALA v. PCIT As the case of the assessee was selected for complete scrutiny, the assessing officer should have verified the above issues for the assessment year under consideration during the course of assessment proceedings. Such failure

Bk Garden Fresh Private Ltd., Kolkata vs. ITO, Ward 7(1), Kolkata

In the result, the appeal of the assessee is allowed on the two issues as discussed above and allowed on the third issue for statistical purposes

ITA 545/KOL/2025[2017-18]Status: DisposedITAT Kolkata18 Nov 2025AY 2017-18

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2017-18 Bk Garden Fresh Pvt. Ltd.……………………………………….……….……Appellant 12, Ramlochan Mullick Street, Kol-700007. [Pan: Aafcb6953P] Vs. Ito, Ward-7(1), Kolkata..………………………………….....……...…..…..Respondent Appearances By: Shri N. S. Saini, Ar & Satyaki Mondal, Ca, Appeared On Behalf Of The Appellant. Shri Subrata Aich, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 15, 2025 Date Of Pronouncing The Order : November 18, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 10.02.2025 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. Brief Facts Of The Case Are That The Assessee Filed Return Of Income Declaring Total Income Of Rs.10,31,194/-. The Case Of The Assessee Was Selected For Complete Scrutiny Specifically On The Ground Of Large Cash Deposits During Demonetisation Period. Notices U/S 143(2) & 142(1) Along With Questionnaire Were Issued & After Considering The Submissions & Details Submitted By The Assessee, The Assessing Officer Assessed Total Income At Rs.90,47,322/- After Making The Following Additions: Bk Garden Fresh Pvt. Ltd 1. Bad Debts Rs.90,006/- 2. Cash Discount Rs.95,622/- 3. Charity & Donation Rs.50,500/- 4. Disallowed On Cash Deposits At Rs.77,80,000/- U/S 69A

Section 143(2)Section 250Section 36(1)(vii)Section 69A

case are that the assessee filed return of income declaring total income of Rs.10,31,194/-. The case of the assessee was selected for complete scrutiny specifically on the ground of large cash deposits during demonetisation period. Notices u/s 143(2) and 142(1) along with questionnaire were issued

Dakshin Kalikata Sansad, Kolkata vs. I.T.O., Ward - 1(2), Exemption, Kolkata

In the result, appeal of the assessee stands allowed

ITA 1576/KOL/2025[2018-2019]Status: DisposedITAT Kolkata18 Nov 2025AY 2018-2019

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 1576/Kol/2025 Assessment Year: 2018-2019 Dakshin Kalikata Sansad,….…..……...……Appellant 93/1B, Rash Behari Avenue, Kolkata-700029 [Pan:Aaatd5902A] -Vs.- Income Tax Officer,…………………………..…..Respondent Ward-1(2), Exemption, Kolkata

Section 12ASection 142(1)Section 143(2)Section 143(3)Section 234BSection 270ASection 57

Trust, which filed its return of income for the assessment year 2018-19 disclosing total income at Rs.38,410/-. The case was selected for complete scrutiny under CASS. Notice under section 143(2) was issued and duly served upon the assessee. Notice under section 142(1) along with questionnaire dated

Bharat Serums and Vaccines Limited, Mumbai vs. Deputy Commissioner of Income Tax - Circle 15(1)(2), Mumbai

In the result, grounds of appeal raised by the assessee are allowed

ITA 2780/MUM/2025[2020-2021]Status: DisposedITAT Mumbai18 Nov 2025AY 2020-2021

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarbharat Serums & V/S. Deputy Commissioner Of Vaccines Limited बनाम Income Tax, Circle – 15(1)(2), 3Rd Floor, Liberty Tower, Aayakar Bhavan, Mumbai – Airoli, Navi Mumbai – 400 020, Maharashtra 400708, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaacb2431M Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Manoj Mundra,ARFor Respondent: Shri Leyaqat Ali Aafaqui (Sr.DR)

Section 142(1)Section 143(3)Section 263Section 37(1)Section 80GSection 80G(5)

also has an approved research facility. The assessee company filed its return of income for the captioned assessment year which was selected for complete scrutiny through CASS and accordingly, notices u/s 143(2) and 142(1) of Act were issued against which the assessee duly made submissions from time ... that deduction claimed under chapter VI-A was one of the issues due to which the assessee’s return of income was selected for complete scrutiny. Where the very basis of selecting assessee’s case for scrutiny was deduction claimed under Chapter VI-A, it could not be stated that

Mahesh Vishwas Tudavekar, Kolar vs. ITO, Ward - 1, Belgaum

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

ITA 336/PAN/2025[2017-18]Status: DisposedITAT Panaji17 Nov 2025AY 2017-18

Bench: Shri Pavan Kumar Gadalei T A. No.336/Pan/2025 (A.Y. 2017-18 ) Mahesh Vishwas Tudavekar, Vs Ito-Ward-5, 1505,Kudasammanavar Galli, Feroj Khimjibhai Cpx, . Bailhongal, Civil Hospital Road Belgavi-591102, Belagavi-590001. Karnataka. Karnataka. Pan .No. Aiwpt1145P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Rs.3,42,920/- after claiming chapter VIA deduction of Rs.13,90,000/-. Subsequently the case was 2 ITA. No.336/PAN/2025 Mahesh Vishwas Tudavekar. selected for complete scrutiny under CASS and the Assessing Officer(A.O) has issued notice u/sec143(2) and u/sec 142(1) of the Act to substantiate the claims supporting

Sureshkumar Manchandbhai Shah, Palanpur vs. The ACIT, Circle-1, Palanpur

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

ITA 1336/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad17 Nov 2025AY 2017-18

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

For Appellant: Shri S.N. Divatia, A.R. &For Respondent: Shri Alpesh Parmar, CIT-D.R

Section 142(1)Section 143(1)Section 250Section 694Section 69A

declaring total income of Rs. 19,06,770/-. The said return was processed u/s. 143(1) of the Act. The case was selected for complete scrutiny and notice u/s. I.T.A No. 1336/Ahd/2025 Sureshkumar Manchandbhai Shah, A.Y. 2017-18 143(2) was issued on 13-08-2018. Notice

Anupam Industries Limited, Anand vs. The ACIT, Anand Circle, Anand

The appeal of the Department is dismissed

ITA 1882/AHD/2024[2022-23]Status: DisposedITAT Ahmedabad17 Nov 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Alpesh Parmar, CIT-DRFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 143(3)

assessee filed a belated return of income for A.Y. 2017-18 declaring a loss of Rs. 90,10,283/-. The case was selected for complete scrutiny under CASS and the Assessing Officer completed the assessment under section 143(3) on 23.12.2019 assessing the total income

Anupam Industries Limited, Anand vs. The ACIT, Ananad Circle, Anand

The appeal of the Department is dismissed

ITA 982/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad17 Nov 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Alpesh Parmar, CIT-DRFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 143(3)

Anupam Industries Limited, Anand vs. The ACIT, Anand Circle, Anand

The appeal of the Department is dismissed

ITA 981/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad17 Nov 2025AY 2014-15

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Alpesh Parmar, CIT-DRFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 143(3)

Assistant Commissioner of Income Tax, Anand Circle, Anand vs. Anupam Industries Limited, Anand

The appeal of the Department is dismissed

ITA 1015/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad17 Nov 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Alpesh Parmar, CIT-DRFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 143(3)

Jayashree Sanjay Jadhav, Mumbai City vs. Assistant Commissioner of Income Tax, Circle 42 (2) (3), Mumbai

In the result, the Assessee’s appeal is allowed in the said terms

ITA 5660/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Nov 2025AY 2017-18

Bench: Shri Narender Kumar Choudhryassessment Year: 2017-18 Ms. Jayashree Sanjay Acit, Circle 42(2)(3), Jadhav, Kautalya Bhavan, Bandra H 11/703, Palm Acres Chs Ltd. Vs. Kurla Complex, Pratiksha Nagar, Sion, Bandra (East), Mumbai – 400022. Mumbai - 400051 Pan: Adgpj9973J (Appellant) (Respondent) Present For: Assessee By : Shri Anant Pai, Ld. A.R. Revenue By : Shri Vikas Chandra, Ld. Sr. D.R. Date Of Hearing : 17.11.2025 Date Of Pronouncement : 17.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 31.07.2025, Impugned Herein, Passed By Ld. Commissioner Of Income Tax (Appeals) Addl/Jcit (A) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2008-09. 2. Admittedly, The Case Of The Assessee Was Selected For Scrutiny For The Following Issues: (I) Cash Deposit In The Bank Account During Demonetization Period From 09.11.2016 To 31.12.2016. (Ii) Transactions Made In Immovable Property & (Iii) Investment Of Rs.1,50,000/- U/S 80C.

For Appellant: Shri Anant Pai, Ld. A.RFor Respondent: Shri Vikas Chandra, Ld. Sr. D.R

Section 143(3)Section 250Section 69ASection 80C

period from 09.11.2016 to 31.12.2016 only, as the case was selected for limited scrutiny of the issues mentioned above and was not converted complete scrutiny. However, the AO still made the addition of Rs.15,04,500/- by considering the deposit made even outside the purview of the demonetization period

Raheja Sherwood Cooperative Housing Society Ltd, Mumbai vs. ITO Ward 41(4)(3), Mumbai

Appeal is allowed for statistical purposes

ITA 5228/MUM/2025[2020-21]Status: DisposedITAT Mumbai17 Nov 2025AY 2020-21

Bench: Shri Narender Kumar Choudhryassessment Year: 2020-21 M/S. Raheja Sherwood Ito Ward 41 (4) (3), Cooperative Housing Society C41-43, G Block Bkc, Ltd., Gilban Area, Nirlon Compound, Vs. Bandra Kurla Complex, Western Express Highway, Bandra East, Goregaon East, Mumbai - 400051 Mumbai – 400063. Pan: Aabtr1763L (Appellant) (Respondent) Present For: Assessee By : Shri Kinjal Bhuta, Ld. A.R. Revenue By : Shri Praveen K. Srivastav, Ld. Sr. D.R. Date Of Hearing : 17.11.2025 Date Of Pronouncement : 17.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 27.06.2025, Impugned Herein, Passed By The National Faceless Appeal Center (Nfac)/ Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2020-21. 2. In This Case, The Assessee Had Declared Its Total Income At Rs.38,15,171/- & Claimed The Deduction Of Rs. Rs.35,10,843/- U/S 80P(2)(D) Of The Act, By Filing Its Return Of Income For The A.Y Under Consideration On Dated 09/01/2021, Which Was Subsequently Selected For Complete Scrutiny Under Cass & Resulted Into Assessing The Income Of The Assessee To The Rs.17,16,067/- While Disallowing Of Deduction Claimed U/S 2 M/S. Raheja Sherwood Cooperative Housing Society Ltd.

For Appellant: Shri Kinjal Bhuta, Ld. A.RFor Respondent: Shri Praveen K. Srivastav, Ld. Sr. D.R

Section 139(5)Section 143Section 2Section 250Section 80P(2)(D)

filing its return of income for the A.Y under consideration on dated 09/01/2021, which was subsequently selected for complete scrutiny under CASS and resulted into assessing the income of the assessee to the Rs.17,16,067/- while disallowing of deduction claimed u/s 2 M/s. Raheja Sherwood Cooperative Housing Society

Ador Welding Limited (Successor of Ador Fontech Limited), Mumbai vs. Deputy Commissioner of Income Tax, Circle 2(1)(1), Mumbai

In the result, we set-aside the order of the Ld

ITA 3338/MUM/2025[2021-22]Status: DisposedITAT Mumbai17 Nov 2025AY 2021-22

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeassessment Year : 2021-22 Ador Welding Limited Deputy Commissioner Of (Successor Of Ador Fontech Limited), Income Tax, Ador House, Vs. Circle-2(1)(1), 6 K Dubash Marg, Fort, Room No. 561, 5Th Floor, Mumbai-400001. Aayakar Bhavan, Pan : Aaaca9076B Maharshi Karve Road, Mumbai-400020. (Appellant) (Respondent)

For Appellant: Ms. Rupal KakuFor Respondent: Shri Surendra Mohan, Sr.DR

Section 142(1)Section 143(2)Section 143(3)Section 69A

assessee is in appeal before us. 4. During the course of hearing, the Ld.AR submitted that the case of the assessee was selected for complete scrutiny assessment u/s.143(3) of the Act pursuant to notice u/s.143(2) issued on 27-06-2022 by the Faceless Assessment Centre. Subsequently, a notice

Ganga Bishan, Gurgaon vs. ITO Ward 1(3), Gurgaon

In the result, appeal of the assessee is allowed

ITA 2179/DEL/2025[2019-20]Status: DisposedITAT Delhi17 Nov 2025AY 2019-20

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: NoneFor Respondent: Sh. Ajay Kumar Arora, Sr. 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

Chander Sekhar Pahariya, Bhander vs. Assessing Officer, Gwalior

In the result, appeal is allowed for statistical purposes

ITA 207/AGR/2025[2017-2018]Status: DisposedITAT Agra14 Nov 2025AY 2017-2018

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

Section 143(1)Section 143(2)Section 143(3)Section 250Section 68Section 69Section 69A

declaring total income of Rs.9,69,150/-. Return was processed u/s. 143(1) of the Act. Subsequently, the return was selected for complete scrutiny under computer aided scrutiny selection (CASS) to examine “large turnover shown in ITR but audit report (3CD form) not filed”. Statutory notices

Anita Gurumukh Gidwani, Sangli vs. ACIT, Circle, Sangli

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

ITA 1162/PUN/2025[2017-18]Status: DisposedITAT Pune14 Nov 2025AY 2017-18

Bench: Shri Manish Borad & Shri Vijay Bhamore

For Appellant: NoneFor Respondent: Shri Uodol Raj Singh, DR

Section 144Section 250

return for the A.Y. 2017-18 furnished on 31/03/2018. The case of the assessee as selected for complete scrutiny under CASS. The assessee in spite of being served with valid statutory notices, failed to respond, as a result of which, the AO passed the best judgment assessment making the additions

My Home Industries Private Limited, Hyderabad vs. DCIT., Circle-5(1), Hyderabad

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

ITA 289/HYD/2024[2018-2019]Status: DisposedITAT Hyderabad14 Nov 2025AY 2018-2019

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.289/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2018-19) My Home Industries Vs. Dy.Cit Private Limited, Hyderabad Circle 5(1) Pan: Aabcm9480C Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate A.V. Raghuram राज" व "ारा/Revenue By:: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 28/10/2025 घोषणा की तारीख/Pronouncement: 14/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By My Home Industries Private Limited, (“The Assessee”), Feeling Aggrieved By The Assessment Order Passed By The Learned Commissioner Of Income Tax (Appeals)-10, Hyderabad (“Ld. Cit(A)”) Dated 29.01.2024 For The A.Y 2018-19. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Advocate A.V. RaghuramFor Respondent: : Dr. Narendra Kumar Naik, CIT (DR)

Section 143(2)Section 143(3)Section 144CSection 14ASection 92C

Assessment Year 2018–19 on 31.10.2018, declaring a total income of Rs.120,24,30,930/-. The case of the assessee was selected for complete scrutiny, and accordingly, a notice under section 143(2) of the Income Tax Act, 1961 (“the Act”) was issued by the Learned Assessing Officer

Signode India Limited, Hyderabad vs. ACIT, Circle-3(1), Hyderabad

ITA 240/HYD/2023[2015-16]Status: DisposedITAT Hyderabad14 Nov 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri H. SrinivasuluFor Respondent: Dr. Narendra Kumar Naik, CIT-DR

Section 143(3)Section 144C(5)Section 32

assessee company has declared book profit u/sec.115JB of the Income Tax Act, 1961 amounting to Rs.17,81,16,512/-. The case was selected for complete scrutiny under CASS. Therefore, the Assessing Officer issued notice u/sec.143(2) of the Act through online 7 ITA.No.434/Hyd/2021 & ITA 240/Hyd/2023 M/s. Signode India Limited

Signode India Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle-3(1), Hyderabad

ITA 434/HYD/2021[2016-17]Status: DisposedITAT Hyderabad14 Nov 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri H. SrinivasuluFor Respondent: Dr. Narendra Kumar Naik, CIT-DR

Section 143(3)Section 144C(5)Section 32

Azim Hasham Premji, Bangalore vs. DCIT, Circle-7(1)(1), Bangalore

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

ITA 1323/BANG/2025[2021-22]Status: DisposedITAT Bangalore14 Nov 2025AY 2021-22

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Sandeep Huligal, AdvocateFor Respondent: Dr. Thejaswi G V, JCIT-DR

Section 10Section 142(1)Section 143(2)Section 23Section 23(1)Section 23(1)(c)Section 250

appeal.” 3. The brief facts of the case are that the assessee filed his return of income on 15/01/2021. The case was selected for complete scrutiny and notice u/s. 143(2) was issued. Subsequently, notice u/s. 142(1) was also issued. The AO on the basis that the assessee