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“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

Arup Kumar Chatterjee, Kolkata vs. I.T.O., Ward - 26(4), Kolkata

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

ITA 1821/KOL/2025[2017-2018]Status: DisposedITAT Kolkata27 Oct 2025AY 2017-2018

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2017-18 Arup Kr. Chatterjee……………………………………………….…….……Appellant 22A, Hemchandra Mukherjee Road, Barish Kolkata-8. [Pan: Afmpc1447G] Vs. Ito, Ward-26(4), Kolkata..………………………..………...……...…..…..Respondent Appearances By: Shri Ankit Jalan, Ar, Appeared On Behalf Of The Appellant. Shri Pankaj Pandey, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 14, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 18.06.25 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”). Brief Facts Of The Case Are That In This Case, The Assessee Had Filed 2. His Return Of Income On 30.10.2017 For A.Y. 2017-18 Declaring Total Income Of Rs. 6,15,590/-. Further The Assessee Filed Revised Return Showing Total Income Of Rs. 4,50,220/-. The Case Of The Assessee Was Selected For Complete Scrutiny Under Cass With A Reason 'Large Sales Promotion Expenses Vis-Is Gross Receipts'. Notice U/S 143(2) Of The It Act Was Issued On 22.09.2019 & Served Upon The Appellant. Notices U/S 142(1) Of The Act Were Issued Time To Time. The Ao Completed The Arup Kr. Chatterjee Assessment Proceedings U/S 143(3) Of The Act On 28.12.2019 & Assessed The Appellant'S Total Income Of Rs.1,23,67,640/- By Making Addition Of Rs.1,23,77,644/- On Account Of Business & Profession.

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

Further the assessee filed revised return showing total income of Rs. 4,50,220/-. The case of the assessee was selected for complete scrutiny under CASS with a reason 'Large Sales promotion expenses vis-is gross receipts'. Notice u/s 143(2) of the IT Act was issued