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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

Shri Venkateshwar Urban Credit Souhard Sahakari Limited, 1210, Athani H.O, Athni, Belgaum, 591304, Karnatak vs. Income Tax Officer, Belgaum

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

ITA 206/PAN/2025[2017-2018]Status: DisposedITAT Panaji15 Sept 2025AY 2017-2018

Bench: Shri Pavan Kumar Gadalei T A. Nos.206/Pan/2025 (A.Y. 2017-18 ) Shri Venkateshwar Urban Vs Ito-Ward-3, Credit Souhard Sahakari Ltd, Feroj Khimjibhai Cpx, . 1210,Athani, H.O.Athani, Civil Hospital Road Belagavi-591304, Belagavi-590001. Karnataka. Karnataka. . Pan .No. Aacas1356G (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Jaykumar Patil.Ar Revenue By Smt.Manju Thakur.Sr.Dr सुनवाई की तारीख/Date Of Hearing 10.09.2025 15.09.2025 घोषणा की तारीख/Date Of Pronouncement Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of Addl/Jcit (A)-2 Jaipur Passed U/Sec 143(3) & U/Sec 250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Ex-Parte Order Of The Cit(A) Sustaining The Denial Of Claim Of Deduction U/Sec80P(2)(A)(I) Of The Act Made By The Assessing Officer. 2. The Brief Facts Of The Case Are That, The Assessee Is A Cooperative Credit Society & Is Engaged In Activities Of Providing Credit Facilities To Its Members. The Assesse Has Filed The Return Of Income For The A.Y 2017-18 On 25.01.2018 Disclosing A Total Income Of Rs.Nil After

Section 80P

Shri Venkateshwar Urban Credit Souhard Sahakari Ltd. claiming deduction of Rs.18,54,940/- u/sec 80P of the Act. Subsequently the case was selected for complete scrutiny under CASS to examine (i) Low income in comparison to high loans/advances/investment in shares appearing in balance sheet and (ii) Large deduction Under Chapter