“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

Deputy Commissioner of Income Tax, Circle-3(1)(1), Ahmedabd, Ahmedabad, Gujarat vs. Hemantkumar Rajendrakumar Shah, Ahmedabad, Gujarat

In the result, the appeal file by the Revenue is dismissed

ITA 1371/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad10 Mar 2026AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamble

For Appellant: Shri Akhilendra Pratap Yadaw, CIT. DRFor Respondent: Ms Urvashi Shodhan, AR

Section 143(2)Section 143(3)Section 145(3)Section 68

that the assessee filed his return of income for the AY 2018-19 declaring total income at Nil. The case was selected for complete scrutiny under CASS to verify the issue that the assessee has not furnished (i) quantitative details of stock withheld (ii) Securities (Derivative) Transaction (iii) details

Asst Commissioner of Income Tax, Panvel vs. Epygen Biotech Private Limited, Navi Mumbai

In the result, appeal of the Revenue is allowed

ITA 2719/PUN/2024[2018-19]Status: DisposedITAT Pune10 Mar 2026AY 2018-19

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Satya Prakash Singh, CAFor Respondent: Shri Nasavarak Jore,atj, Addl.CIT

Section 143(2)Section 143(3)Section 250Section 35(1)(iv)

immune disorders. Loss of ₹ 5,25,98,291/- declared in the return for A.Y. 2018-19 e-filed on 28.11.2018. Case selected for complete scrutiny on two issues, namely, business loss and large deduction claimed on account of scientific research u/s. 35(1)(iv) of the Act. Valid statutory notices

Nobel Automotive India Private Limited, Kancheepuram vs. DCIT, Corp Circle 4(1), Chennai

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

ITA 2009/CHNY/2025[2022-23]Status: DisposedITAT Chennai09 Mar 2026AY 2022-23

Bench: Shri Aby T Varkey & Shri S.R. Raghunatha

For Appellant: Shri. Bipin C.N, CITFor Respondent: 19.01.2026

Section 143(3)Section 40

accessories. The assessee filed its return of income on 15.11.2022 declaring a total income of Rs.NIL for the A.Y.2022-23. The case was selected for complete scrutiny assessment and accordingly the AO issued statutory notices to the assessee. During the assessment proceedings the AO noticed that the assessee has claimed

Dharmbati, Faridabad vs. Income Tax Inspector Faridabad, Faridabad

In the result, appeal of the assessee is allowed

ITA 5672/DEL/2025[2018-19]Status: DisposedITAT Delhi05 Mar 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2018-19 Dharmbati, Vs. Income Tax Inspector, H. No. 523, Chandawali, Faridabad Ballabhgarh, Faridabad Pan: Azipb6400G (Appellant) (Respondent) Assessee By None Department By Ms. Monika Singh, Cit(Dr) Date Of Hearing 05.03.2026 Date Of Pronouncement 05.03.2026 Order Per Satbeer Singh Godara, Jm This Assessee’S Appeal For Assessment Year 2018-19, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The “Cit(A)/Nfac”], Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1077406804(1), Dated 23.06.2025 Involving Proceedings Under Section 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Case Called Twice. None Appears At The Assessee’S Behest. He Is Accordingly Proceeded Ex-Parte. 2. It Emerges During The Course Of Hearing That The Sole Substantive Issue Between The Parties Is That Of Correctness Of The Learned Lower Authorities’ Action Assessing The Assessee’S Interest Component Of Land Acquisition Compensation U/S 28 Of The Land Acquisition Act, 1894, While Invoking Section 57(Iv) R.W.S. 56(1)(A) R.W.S. 145A(B) Of The Act. 3. Learned Sr. Dr Representing The Department Vehemently Argued That The Instant Issue Is No More Res Integra In Light Of Mahender Pal Narang Vs. Cbdt (2020) 423 Itr 13 (P&H) As Well As Pcit Vs. Inderjit Singh Sodhi Huf (2024) 161 Taxmann.Com 301 (Del.) Wherein The Department Has Succeeded Before Their Lordships That The Impugned Interest Component Ought To Be Assessed As Income From “Other” Sources Only. 4. We Have Given Our Thoughtful Consideration To The Assessee’S Pleadings & Revenue’S Foregoing Vehement Contention. It Emerges That This Tribunal’S Recent Decision In Pawan Kumar Vs. Pcit (2024) 159 Taxmann.Com 61 (Del.-Trib.) Has Distinguished The Said Case Law As Under:

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(viii)Section 57

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

Kkr India Asset Finance Private Limited, Mumbai vs. Deputy Commissioner of Income-Tax, Corporate Circle 4(1), Chennai

In the result, the appeal of the assessee is allowed

ITA 2881/CHNY/2025[2022-23]Status: DisposedITAT Chennai04 Mar 2026AY 2022-23

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita No.2881/Chny/2025 िनधा#रण वष# /Assessment Year: 2022-23

For Appellant: Mr. Niraj Sheth, AdvocateFor Respondent: Mr. ARV Srinivasan, CIT for Mr. Bipin C.N. CIT

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250

income for the A.Y. 2022-23 on 04.11.2022 declaring Income of Rs.75,15,49,137/-. The case of the appellant was selected for complete scrutiny under CASS. Notice u/s 143(2) was issued by AO on 02.06.2023 and duly served upon the assessee. Thereafter, to examine the CASS reason, notices

Vinayaga Fireworks, Sivakasi vs. DCIT, Non Corporate Circle-2, Madurai

In the result the appeal of the assessee is allowed

ITA 2282/CHNY/2025[2017-18]Status: DisposedITAT Chennai03 Mar 2026AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

For Appellant: Shri. V.Rajasekaran, CAFor Respondent: Ms. T. Mythili, JCIT

Section 143(1)Section 68

total income of Rs.31,16,200/- and the same was processed u/s.143(1) of the Act. Subsequently, the return of income was selected for complete scrutiny under CASS to verify the cash deposit of Rs.2,79,71,000/- during the demonetisation period and accordingly the statutory notices were issued

Ramzan Mulla, Vijayapur vs. Income Tax Officer, Ward-2, Vijayapura

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

ITA 1103/BANG/2025[2017-18]Status: DisposedITAT Bangalore03 Mar 2026AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Ms. Jamuna, Advocate

Section 44ASection 69A

44AD of the Act and on that basis, the return of income was filed by him. The case of the assessee was selected for complete scrutiny under CASS to verify the cash deposits made during the demonetisation period. Therefore notice u/s. 143(2) was issued and subsequently, notice

Metrik Infra Projects Private Limited, Bangalore vs. Income Tax Officer, Ward-4(1)(4), Bangalore

In the result, the appeal filed by the assessee is dismissed as infructuous

ITA 125/BANG/2025[2017-18]Status: DisposedITAT Bangalore02 Mar 2026AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Ravishankar, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR

Section 142(1)Section 143(2)Section 234Section 37Section 9

their return of income on 31/10/2017 and incurred a loss of Rs. 2,97,19,347/-. Thereafter the assessee’s case was selected for complete scrutiny under CASS and notices u/s. 143(2) as well as u/s. 142(1) were issued. The AO had proposed to disallow the expenditure incurred

Pioneer Independent Trust, Bangalore vs. Pr. Commissioner of Income Tax, Bengaluru-2, Bengaluru

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

ITA 1143/BANG/2025[2020-21]Status: DisposedITAT Bangalore02 Mar 2026AY 2020-21

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2020-21

For Appellant: Shri Sandeep Huilgol, AdvocateFor Respondent: Shri Muthu Shankar, CIT-DR

Section 142(1)Section 143(2)Section 143(3)Section 263Section 263(1)Section 55(2)(ac)

facts of the case are that the assessee is a trust and filed their return of income on 23/12/2020. The case was selected for complete scrutiny to examine the issue deductions from “Income from Other Sources”. Notices u/s. 143(2) as well as u/s. 142(1) were issued

Karnataka Industrial Areas Development Board, Bangalore vs. Deputy Commissioner Income Tax, Exemptions, Circle-1, Bangalore

ITA 355/BANG/2024[2017-18]Status: DisposedITAT Bangalore02 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Sudheendra B.R, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT-DR

Section 11Section 11(1)Section 13(8)Section 143(3)Section 153(1)Section 2(15)Section 250Section 43B

entire income as exempt u/s. 11 of the Act by filing the return of income on 13/02/2017. The said return was selected for complete scrutiny and notice u/s. 143(2) was issued and notices u/s. 142(1) were also issued. In the said notice, the AO was seeking the explanation

Karnataka Industrial Areas Development Board, Bangalore vs. Deputy Commissioner of Income-Tax, Exemptions, Circle-1, Bangalore

ITA 354/BANG/2024[2016-17]Status: DisposedITAT Bangalore02 Mar 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Sudheendra B.R, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT-DR

Section 11Section 11(1)Section 13(8)Section 143(3)Section 153(1)Section 2(15)Section 250Section 43B

Sidharth Buildwell LLP, Dehradun vs. ACIT, C- 1(2)(1), Dehradun

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

ITA 129/DDN/2024[2017-18]Status: DisposedITAT Dehradun27 Feb 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmansidharth Buildwell Llp Vs. Acit, 1, Darshiningate, Kanwali, Circle 1(2)(1), Kanwali B.O. Dehradun Haripuram, Dehradun Pan: Acufs6966M (Appellant) (Respondent) Assessee By: Ms. Komal Sachev, Ca Revenue By: Sh. A.S.Rana, Sr. Dr Date Of Hearing: 14.01.2026 Date Of Order : 27.02.2026 Order Per S. Rifaur Rahman: The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Ld. Cit(A)”, For Short] Dated 07.06.2024 For The Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income On 07.11.2017 Declaring Income At Rs. 95,08,920/- For Assessment Year 2017- 18. The Case Was Selected For Complete Scrutiny Through Cass With The Reasons “Higher Turnover Reported In Service Tax Return As Compared To Itr, Large Increase In Unsecured Loans During The Year, Real Estate Business

For Appellant: Ms. Komal Sachev, CAFor Respondent: Sh. A.S.Rana, Sr. DR

Section 115BSection 133(6)Section 142(1)Section 143(2)Section 68

filed its return of income on 07.11.2017 declaring income at Rs. 95,08,920/- for assessment year 2017- 18. The case was selected for complete scrutiny through CASS with the reasons “Higher turnover reported in Service Tax Return as compared to ITR, Large increase in unsecured loans during the year

Narendra Kumar Mishra, Bhopal vs. ITO-3(1), Bhopal

Appeal is partly allowed for statistical purpose

ITA 233/IND/2025[2020-21]Status: DisposedITAT Indore27 Feb 2026AY 2020-21

Bench: Shri B.M. Biyani

For Appellant: Narendra Kumar Mishra, Bhopal

Section 143(3)Section 253(5)

without any change. Page 4 of 43 (iii) Narendra Kumar Mishra ITA No. 233/Ind/2025 - AY 2020-21 The case of assessee was selected for complete scrutiny under CASS and statutory notices u/s 143(2)/142(1) were issued from time to time which were responded by assessee. During scrutiny proceedings

Hrj International Private Limited, Indore vs. PCIT Indore-1, Indore

Appeal is dismissed

ITA 252/IND/2024[2018-19]Status: DisposedITAT Indore27 Feb 2026AY 2018-19

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2018-19 Hrj International Pvt. Ltd., Pr. Cit 7/2 Indore Trade Centre, Indore South Tukoganj बनाम/ Nr. Nehru Statue Vs. Indore (Assessee/Appellant) (Revenue/Respondent) Pan: Aacch4574K Assessee By Shri Sudhir Padliya, Ar Revenue By Shri Anup Singh, Cit-Dr Date Of Hearing 19.02.2026 Date Of Pronouncement 27/02/2026

Section 142(1)Section 143(3)Section 263Section 68

liable to be added as unexplained cash credit of Rs. 7,85,79,439/- u/s 68 to the total income of the assessee by completing scrutiny assessment proceedings. 5. On further perusal of record, it is evident that the case of the assessee company was selected for complete scrutiny with

Js Engineering Works, Sawa, Chittorgarh vs. DCIT, Central Circle, Chittorgarh

In the result, all these 6 appeals filed by the assessee are allowed

ITA 628/JODH/2024[2017-18]Status: DisposedITAT Jodhpur26 Feb 2026AY 2017-18

Bench: Dr. Mitha Lal Meena, Hon’Ble & Sudhir Pareek, Hon’Blestay Application No. 8 To 13/Jodh/2024 (Arising Out Of Ita Nos. 620, 621, 622, 624, 625 &628/Jodh/2024) (Assessment Year – 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 & 2017-18) Js Engineering Works Dcit, Central Circle, J-16, M/S. Sclj & Associates, Chittorgarh. Lal Kothi Yojana, Sahakar Marg, Jaipur – 302015. Pan No. Aaffj 9260 Q

Section 131(3)Section 133ASection 143(3)Section 144Section 148Section 263

verified. It is noted that for the 9 622/Jodh/2024 & Others Assessment Years 2012-13 to 2017-18 Assessment Years 2012-13 & 2013-14, complete scrutiny assessment had taken place u/s 143(3). The assessee has submitted the invoices raised on the customers wherein the details of number of labours