“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, Jaipur vs. Samarth Lifestyle Retailing Pvt. Ltd., Jaipur

ITA 1196/JPR/2025[2018-19]Status: DisposedITAT Jaipur13 Oct 2025AY 2018-19

For Appellant: Shri P. C. Parwal, Learned C.AFor Respondent: Shri Rajesh Ojha, Learned CIT

Section 142(1)Section 143(2)Section 250Section 40(2)(b)

year 2018-19 was filed by the assessee declaring its income of Rs.1,59,34,420/-. 5. Case of the assessee was selected for complete scrutiny through CASS, on the following issues:- "1. Low receipts from house property in ITR as compared to rental receipts in 26AS. 2. Low income

Ceigall India Limited, Ludhiana vs. Principal Commissioner of Income Tax, Ludhiana

In the result, the appeal of the assessee stands allowed

ITA 540/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh13 Oct 2025AY 2020-21

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Tarundeep Kaur, CIT, DR(Virtual)

Section 143(2)Section 143(3)Section 263

accounts. The AO examined and recorded his satisfaction. 3.10 The AR argued that this was never a CASS issue. Without converting the case into “complete scrutiny”, the PCIT could not travel beyond the limited scrutiny scope. Moreover, purchases were reflected in audited accounts and routed through banking channels

Brahm Precision Materials Pvt. Ltd., Aurangabad vs. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, New Delhi

In the result, appeal of the assessee for A

ITA 425/PUN/2025[2020-21]Status: DisposedITAT Pune13 Oct 2025AY 2020-21

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1183/Pun/2023 And

Section 143(3)Section 250Section 68

filed on 28.11.2018 declaring loss of Rs.6,67,235/-. Return processed u/s.143(1) of the Act on 04.11.2019. Subsequently, case selected for Complete Scrutiny on account of the three issues namely : (a) Claim of Any Other Amount Allowable as deduction in Schedule BP (b) Non-Furnishing of Quantitative details

Brahm Precision Materials Pvt Ltd, Aurangabad vs. CIT(A), National Faceless Appeal Centre (NFAC) Delhi

In the result, appeal of the assessee for A

ITA 1183/PUN/2023[2018-19]Status: DisposedITAT Pune13 Oct 2025AY 2018-19

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1183/Pun/2023 And

Section 143(3)Section 250Section 68

Krishnasamy Ilangovan, Namakkal vs. ITO, Ward-2, Namakkal

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

ITA 2066/CHNY/2025[2017-18]Status: DisposedITAT Chennai13 Oct 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 2066/Chny/2025 िनधा(रण वष( / Assessment Year: 2017-18 Krishnasamy Ilangovan, Income Tax Officer, 2/3, East Street Sruthi Agencies, Vs. Ward-2, Nallipalayam, Namakkal. Namakkal – 637 003. Tamil Nadu. [Pan: Aaipi-1366-F] (अपीलाथ*/Appellant) (+,थ*/Respondent) अपीलाथ* की ओर से/Appellant By : Mr. Girish Kumar S, Advocate For Mr. S. Sridhar, Advocate. +,थ* की ओर से/Respondent By : Ms. Anitha, Addl. Cit.

For Appellant: Mr. Girish Kumar S, Advocate for Mr. S. Sridhar, AdvocateFor Respondent: Ms. Anitha, Addl. CIT

Section 144Section 44ASection 69A

Rs.12,74,080/- into his savings bank account maintained with United Commercial Bank, Namakkal during the demonetization period. The case was selected for complete scrutiny and statutory notices were issued to the assessee and assessee did not respond for many notices initially. In response to the proposed Assessment Notice dated

Sanjay Malhotra, New Delhi vs. ITO, Ward-29(3), Delhi

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

ITA 2255/DEL/2024[2017-18]Status: DisposedITAT Delhi13 Oct 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmansanjay Malhotra, Vs. Ito, Ward 29 (3), Hs – 23, Second Floor, Kailash Colony, Delhi. New Delhi – 122 002. (Pan : Aaipm0514F) (Appellant) (Respondent) Assessee By : Shri K. Sampath, Advocate Shri V. Rajkumar, Advocate Revenue By : Shri Manish Gupta, Sr. Dr Date Of Hearing : 17.07.2025 Date Of Order : 13.10.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of The Ld. Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [For Short ‘Ld. Cit (A)] For The Assessment Year 2017-18. 2. Brief Facts Of The Case Are, Assessee Filed Its Return Of Income For Assessment Year 2017-18 On 27.10.2017 Declaring An Income Of Rs.15,06,840/-. The Case Was Selected For Complete Scrutiny Under Cass. Notices Under Section 143(2) & 142(1) Of The Income-Tax Act

For Appellant: Shri K. Sampath, AdvocateFor Respondent: Shri Manish Gupta, Sr. DR

Section 142(1)Section 143(2)

filed its return of income for Assessment Year 2017-18 on 27.10.2017 declaring an income of Rs.15,06,840/-. The case was selected for complete scrutiny under CASS. Notices under section 143(2) and 142(1) of the Income-tax Act, 2 1961 (for short ‘the Act’) were issued

Shivansh Dairy Products Private Limited, New Delhi vs. Income Tax Officer, Delhi

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

ITA 1087/DEL/2024[2017-18]Status: DisposedITAT Delhi13 Oct 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanshivansh Dairy Products Private Limited, Vs. Income Tax Officer, 26/6, Plot No.4, Nangli Sakrawati Indl. Area, Delhi. Near Main Najafgarh Road, New Delhi – 110 043. (Pan : Aarcs9344P) (Appellant) (Respondent) Assessee By : Shri Shantanu Jain, Advocate Shri Deepanshu Jain, Advocate Revenue By : Shri Manish Gupta, Sr. Dr Date Of Hearing : 15.07.2025 Date Of Order : 13.10.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Order Of The Ld. Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [For Short ‘The Ld. Cit (A)] Dated 11.01.2024 For Ay 2017-18. 2. Brief Facts Of The Case Are, Assessee Filed Its Return Of Income On 21.11.2017 Declaring Total Income Of Rs.6,16,930/-. The Case Was Selected For Complete Scrutiny Through Cass For The Following Reason :- “Abnormal Increase In Cash Deposits During Demonetization Period As Compared To Pre-Demonetization Period.”

For Appellant: Shri Shantanu Jain, AdvocateFor Respondent: Shri Manish Gupta, Sr. DR

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

case are, assessee filed its return of income on 21.11.2017 declaring total income of Rs.6,16,930/-. The case was selected for complete scrutiny through CASS for the following reason :- “abnormal increase in cash deposits during demonetization period as compared to pre-demonetization period.” 2 3. Notices under section

DCIT, Circle-1(1)(1), Ahmedabad vs. Atul Limited, Ahmedabad

In the result, the appeal of the Revenue is dismissed

ITA 1774/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaassessment Year: 2016-17

Section 271GSection 92CSection 92DSection 92D(3)

return of income for the A.Y. 2016-17 on 25.11.2016 declaring total income of Rs.301,28,45,510/-. The case was selected for complete scrutiny under CASS. The Assessing Officer noticed that the assessee had entered into DCIT vs. Atul Limited Page 2 of 11 certain international transactions and specified

Bakeri Projects Private Limited, Ahmedabad vs. The Dy.CIT, Circle-1(1)(1), Ahmedabad

In the result, the appeals of the assessee on this ground are allowed

ITA 785/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2016-17

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2016-17

For Appellant: Shri S.N. Soparkar, A.RFor Respondent: Shri R.P. Rastogi, CIT-D.R

Section 143(2)Section 271(1)(c)Section 274Section 32Section 32(1)Section 32(1)(ii)Section 43(1)Section 43(6)

income for AY 2016-17 on 7 October 2016 declaring total loss of Rs. 20,91,35,518. The case was selected for complete scrutiny under CASS and a notice for e-proceeding under section 143(2) was generated and duly served to the appellant. During the course

Biochemical and Synthetics Products Private Limited, Hyderabad vs. DCIT., Circle-1(1), Hyderabad

ITA 1306/HYD/2025[2020-21]Status: DisposedITAT Hyderabad10 Oct 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.1306/Hyd/2025 (निर्धारण वर्ष/Assessment Year: 2020-21)

For Appellant: Advocate Bharath JanarthananFor Respondent: : Dr. Sachin Kumar, Sr. DR

assessee filed its return of income on 28.01.2021 declaring total income of Rs.20,30,46,190/-. The case of the assessee was selected for complete scrutiny, and accordingly, the Learned Assessing Officer (“Ld. AO”) issued notice under section 143(2) of the Income

Gandhi Special Tubes Limited, Mumbai vs. ACIT- Circle 5(1)(1), Mumbai

ITA 2421/MUM/2025[2017-2018]Status: DisposedITAT Mumbai10 Oct 2025AY 2017-2018

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Ms. Padmavathy S, Hon’Blegandhi Special Tubes Limited, Asst. Cit Circle 5(1)(1), 201-204, 2Nd Floor Plaza 55, Mumbai. Vs. Hughes Road, Next To Dharam Palace, Mumbai 400 007. Pan Aaacg1261C (Appellant) (Respondent)

For Appellant: S/Shri Chaitanya D Joshi & Saurav SuranaFor Respondent: Shri Swapnil Choudhary-Sr AR

Section 142(1)Section 143(1)Section 80I

Income Tax Act, 1961 (‘Act’ for short) without variation in the income returned. The case was subsequently picked up for complete scrutiny inter alia on the ground of excessive deduction claimed under Section 80I/80IA/80IB/80IC as compared to the turnover. The Assessing Officer issued notice under Section

Pawan Kumar Sharma, New Delhi vs. Assistant Director of Income Tax, Banglore

In the result, appeal of the assessee in ITA No

ITA 2509/DEL/2025[2020-21]Status: DisposedITAT Delhi10 Oct 2025AY 2020-21

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: Shri Sumit Lalchandani, AdvFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR

Section 139(1)Section 143(1)Section 234ASection 36(1)Section 36(1)(va)Section 37

beyond the reasons for scrutiny selection and such cases are called Limited Scrutiny cases and only the remaining returns are taken up for complete scrutiny u/s 143(3) of the Act. 13.2 Meaning thereby, that exercise of power under sub-section (2) of section 143 of the Act leading

DCIT, Circle - 3(1), Visakhapatnam vs. Snf India Private Limited, Visakhapatnam

ITA 210/VIZ/2025[2014-15]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2014-15

Bench: Shri Ravish Sood, Hon'Ble & Shri S Balakrishnan, Hon'Bleआयकर अपीलसं./I.T.A.No.204/Viz/2025 (निर्धारणवर्ष/ Assessment Year:2016-17) M/S. Snf (India) Private Limited 19 Jnpc, Ramky Pharmacity Paravada, Visakhapatnam – 531021 Andhra Pradesh [Pan:Aaacp4070A] Vs. Dcit - Circle – 3(1) Income Tax Office Infinity Towers, Sankarmat Road Visakhapatnam – 530016 Andhra Pradesh आयकर अपीलसं./I.T.A.Nos.209 & 210/Viz/2025 (निर्धारणवर्ष/ Assessment Years:2016-17 & 2014-15) Dcit - Circle – 3(1) 35,50-92-35, Sankaramatam Road Opposite Reliance Fresh, Beside Reliance Fresh, Nearby Main Road Madhuranagar, Dwarakanagar Visakhapatnam – 530016 Vs. M/S. Snf (India) Private Limited Plot No. 19 Ponnuru Village, Parawada Mandal Visakhapatnam – 531021 Andhra Pradesh [Pan:Aaacp4070A] करदाता का प्रतिनिधित्व/ Assessee Represented By राजस्व का प्रतिनिधित्व/ Department Represented By सुनवाई समाप्त होने की तिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/Date Of Pronouncement Shri Kanchan Kaushal, Ca Shri Badicala Yadagiri, Cit(Dr) 01.09.2025 08.10.2025

Section 142(1)Section 143(2)Section 92C

subsequently, revised to Rs.(-)26,82,854/- vide revised return dated Page. No 2 29.03.2018. Subsequently, the case was selected for complete scrutiny under CASS and notice under section 143(2) of Income Tax Act, 1961 (in short 'Act') was issued on 23.08.2018. Thereafter, notice under section

DCIT, Circle - 3(1), Visakhapatnam vs. Snf India Private Limited, Visakhapatnam

ITA 209/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2016-17

Section 142(1)Section 143(2)Section 92C

Deputy Commissioner of Income Tax, Circle 3(1), Visakhapatnam vs. Vizag Re-Bars Private Limited, Visakhapatnam

In the result, the cross objection filed by the assessee is allowed

ITA 428/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2017-18

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.428/Viz/2024 (निर्धारणवर्ा/ Assessment Year: 2017-18) Dy. Cit – Circle – 3(1) Vs. M/S. Vizag Re-Bars Private Limited 35, 50-92-35, Sankara Matam Road Plot No. 1 Ida, Edulapaka Bonangi, Opposite Reliance Fresh Parawada Mandal – 531021 Beside Reliance Fresh, Near By Main Road Andhra Pradesh Madhuranagar, Dwaraka Nagar Visakhapatnam – 530016 [Pan:Aabcv2581M] Andhra Pradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 10(38)Section 115JSection 143(3)Section 147Section 148Section 148A

claiming current year loss at Rs.16,69,92,160/- with deemed income u/s 115JB at Rs (-)137741114 /-. Subsequently, the case was selected for complete scrutiny under CASS and order u/s 143(3) was passed on 27-12-2019 reducing net loss to (- )Rs.16,55,52,257/- and by making certain

Sharmanji Yarns Private Limited, Ludhiana vs. Principal Commissioner of Income Tax-1, Ludhiana

The appeal stand allowed in terms of our above order

ITA 706/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh08 Oct 2025AY 2020-21

Bench: SHRI LALIET KUMAR (Judicial Member), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Ashwani Kumar (CA) -Ld. ARFor Respondent: Smt. Tarundeep Kaur(CIT) – Ld. DR

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

appeal is disposed- off as under. 3. From the case records, it emerges that the assessee’s return of income was subjected to complete scrutiny vide assessment order dated 28-09-2022. During the course of assessment proceedings, various notices were issued to the assessee u/s 142(1) along with ... verify this issue during the course of regular assessment proceedings. On the other issues, it was observed that the case was selected under ‘complete scrutiny’ as against assessee’s claim that the case was selected for ‘limited scrutiny’. On specific issue of stock valuation, the assessee had submitted copies

Mahendrakumar R. Punjabi, Nadiad vs. The ITO, Ward-1, Nadiad

In the result, the appeal of the assessee is allowed

ITA 1108/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad08 Oct 2025AY 2016-17

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

For Appellant: Shri Prithu Parimal, ARFor Respondent: Shri Sudhakar Verma, Sr. DR

Section 143(3)Section 148

similar allegations of suspicious share sale transactions and alleged Asst. Year : 2016-17 - 2– penny stock activities, the Appellant's case was subjected to complete scrutiny under Section 143(3) of the Income Tax Act, 1961 ("the Act"), wherein a NII, assessment order was passed. 2. The authorities below failed

Pitti Holdings Private Limited, Hyderabad vs. ACIT., Central Circle-1(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 450/HYD/2025[2018-19]Status: DisposedITAT Hyderabad08 Oct 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.450/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19) M/S. Pitti Holdings Pvt. Asst. Commissioner Of Vs. Ltd., Hyderabad. Income Tax, Central Circle Pan: Aagcp3824Q 1(1), Hyderabad. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri A. Srinivas, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 09/09/2025 घोषणा की तारीख/Pronouncement: 08/10/2025

For Appellant: Shri A. Srinivas, C.AFor Respondent: Dr. Sachin Kumar, DR

Section 148Section 148A

income for the assessment year 2018-19 on 27-09-2018 and returned current year loss at Rs.1.55,676/-. The case was selected for complete scrutiny under CASS and assessment uls 143(3) was passed on 22-01-2021 by the AD, National e- Assessment Centre, Delhi. The issue

Pankhuri Mishra, Gangtok vs. I.T.O., Ward - 3(1), Gangtok

In the result, the appeal of the assessee is allowed

ITA 1607/KOL/2024[2017-2018]Status: DisposedITAT Kolkata08 Oct 2025AY 2017-2018

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm

Section 143(2)

vehemently submitted that the notice u/s 143(2) of the Act dated 22.09.2018, does not specify whether it is a limited scrutiny or a complete scrutiny or a compulsory manner scrutiny. The Id. AR submitted that the CBDT has issued specific instruction vide instruction no. F. No. 225/157/2017/ITA-II Dated ... other hand submitted that this is a computer- generated notice and the non-mentioning of the fact of either limited or complete scrutiny or compulsory manual scrutiny would not render the issuance of notice u/s 143(2) of the Act as invalid. Therefore, additional ground raised by the assessee

Sanjay Chawla, Chaibasa vs. Pr. CIT, Ranchi

In the result, the appeal of the assessee is allowed

ITA 135/RAN/2025[20-21]Status: DisposedITAT Ranchi07 Oct 2025

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaysanjay Chawla, Pr.C.I.T., Sentola, Chaibasa-833201 (Jharkhand) Ranchi. Vs. Pan No. Acmpc 6808 J Appellant/ Assessee Respondent/ Revenue

Section 142(1)Section 143(2)Section 143(3)Section 2Section 263Section 63

wherein the assessee has been required to furnish its reply in substantiation and corroboration of return of income filed which has been selected under complete scrutiny. The assessee respectfully submits here below:- 1. In this regard it is respectfully submitted that during the financial year 2019-20 corresponding to assessment