“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

Ahmedabad Kadi Vijapur Pragana Shrimali Soni Uttejak Mandal, Gandhinagar vs. The ITO, Ward-Exemption, Palanpur Present Juris. the ITO, Ward-1 (Exemption), Ahmedabad

In the result, the appeal of the assessee is dismissed

ITA 1041/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad04 Sept 2025AY 2017-18

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

For Appellant: Shri Sulabh Padshah, A.RFor Respondent: Shri Kamal Deep Singh, Sr. D.R

Section 12ASection 143(3)

scrutiny. 7. The ld. D.R. submitted that the assessee’s case was selected for scrutiny and it was not a limited but that of complete scrutiny. I.T.A No. 1041/Ahd/2025 Ahmedabad Kadi Vijapur Pragana Shrimali Soni Uttejak Mandal, A.Y. 2017-18 8. We have heard both the parties and perused ... relevant materials available on record. It is pertinent to note that the assessee’s case was a complete scrutiny and though it is not mentioned in the assessment order, the same cannot be treated as limited scrutiny assessment. Thus, the contention of the Ld. A.R. does not sustain. Hence ground

Qader Abdul Razzaque Abdul, Aurangabad vs. Principal Commissioner of Income Tax, Nashik

In the result, the appeal of the assessee is dismissed

ITA 937/PUN/2024[2019-20]Status: DisposedITAT Pune04 Sept 2025AY 2019-20

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.937/Pun/2024 धििाारण वर्ा / Assessment Year : 2019-20 Qader Abdul Razzaque Abdul, Principal Commissioner M/S. Captain Color Home Opp. Of Income Tax, Nashik-1 Bhartiya Hospital Raja Bazar Chh. Vs. Sambhajinagar (Aurangabad), Pin Code-431001 Pan : Acqpk8963L अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Shubham N. Rathi Department By : Shri Amit Bobde Date Of Hearing : 24-06-2025 Date Of 04-09-2025 Pronouncement : आदेश / Order

For Appellant: Shri Shubham N. RathiFor Respondent: Shri Amit Bobde

Section 133ASection 143(2)Section 69

been passed without carrying out any enquiry/verification in relation to the issue for which the case of the assessee was selected for complete scrutiny through CASS. Therefore, the Ld. PCIT was justified in exercising power vested in him to invoke the provisions of section 263 of the Act and direct

ITO-23.2.1, Mumbai vs. Mig Co-Op. Housing Society Group II Limited, Mumbai

ITA 4576/MUM/2025[2017-18]Status: DisposedITAT Mumbai04 Sept 2025AY 2017-18

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalincome Tax Officer, Ward – 23(2)(1) Room No.512, 5Th Floor, Piramal Chambers, Lalbaug, ............... Appellant Mumbai - 400012 V/S Mig Co – Op Housing Society Group Ii Ltd., B-32, Kalpataru Sparkle, Mig Colony, ……………… Respondent Gandhi Nagar, Bandra East, Mumbai - 400051 Pan : Aaaam8129P Assessee By : Shri Yogesh Thar Shri Surajsingh Devda Revenue By : Shri Surendra Mohan, Sr.Dr

For Appellant: Shri Yogesh TharFor Respondent: Shri Surendra Mohan, Sr.DR

Section 142(1)Section 143(2)Section 250Section 80PSection 80P(2)Section 80P(2)(d)

same was claimed as a deduction under section 80P(2)(d) of the Act. The return filed by the assessee was selected for complete scrutiny under CASS, and statutory notices under section 143(2) and section 142(1) of the Act were issued and served on the assessee. During

Fineotex Chemical Limited, Mumbai vs. PCIT-4, Mumbai

In the result, the appeal of the assesse bearing ITA No

ITA 3458/MUM/2025[2020-21]Status: DisposedITAT Mumbai04 Sept 2025AY 2020-21

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjeefineotex Chemical Limited Vs Pcit-4, Room No.629, 6Th Floor, Aayakar 42-43, Manorama Chambers, S.V. Road, Bandra (E), Mumbai- Bhavan, M.K. Road, Mumbai-400 400 050 020 Pan: Aaacf8360M Appellant Respondent

For Appellant: Shri Lalchand ChoudharyFor Respondent: Shri Vivek Perampurna (CIT DR)

Section 143(1)Section 143(3)Section 263Section 40Section 80G

limited scrutiny framework. Upon completion of the prescribed verification, the Ld. AO did not find it necessary to convert the limited scrutiny into complete scrutiny. As per the Instruction of the CBDT, the Assessing Officer is required to restrict his inquiry to the specific parameters forming the basis of selection ... limited scrutiny. Enlargement of the scope of such scrutiny into complete scrutiny is permissible only in revenue-potential cases, upon recording of reasons and obtaining prior approval of the Competent Authority, viz. PCIT/CIT/Pr. DIT. In the present case, no such approval was sought or obtained. Therefore, the issues which could

Prudent Insurance Brokers Private Limited, Mumbai vs. PCIT-8, Mumbai

In the result, the appeal of the assessee stands allowed

ITA 3186/MUM/2025[2020-21]Status: DisposedITAT Mumbai04 Sept 2025AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 263Section 263(1)Section 37Section 37(1)Section 80G

held that the Assessing Officer had failed to properly verify this issue in light of the fact that the case was selected for complete scrutiny. Invoking Explanation 2 to section 263(1), he concluded that the deduction claimed was purely CSR expenditure on which section 80G deduction could

Gangadhar Agarwal, Nizamabad vs. ITO., Ward-1, Nizamabad

ITA 697/HYD/2025[2017-18]Status: DisposedITAT Hyderabad03 Sept 2025AY 2017-18

Section 142(1)Section 143(3)Section 44A

annulled. 3. The Ld. CIT(A) ought to have considered that the AO, while explaining the scope of the issues as that for the complete scrutiny, without obtaining prior approval of the Pr. CIT concerned and thus the assessment is bad in law and needs to be quashed/annulled

Farheez Eruch Aga, Pune vs. Income Tax Officer, Ward-9(1), Pune

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

ITA 1870/PUN/2024[2021-22]Status: DisposedITAT Pune02 Sept 2025AY 2021-22

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22

For Appellant: Shri Kishor PhadkeFor Respondent: Shri Ramnath P Murkunde

Section 133(6)

filed her return of income on 14.12.2021 declaring total income of Rs.11,51,62,460/-. The case of the assessee was selected for complete scrutiny assessment in accordance with the provisions of the E-assessment Scheme on account of large payment as commission to persons who have not filed their

T.Abdul Wahid and Company, Chennai vs. ACIT, Ncc0491), Chennai

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

ITA 1672/CHNY/2025[2018-19]Status: DisposedITAT Chennai02 Sept 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1672/Chny/2025 धनिाारण वर्ा / Assessment Year: 2018-19 T. Abdul Wahid & Company, Assistant Commissioner Of No.55/27, Vepery High Road, Vs. Income Tax, Periamet, Chennai – 600 003. Non-Corporate Circle – 4(1). Tamil Nadu. Chennai. [Pan: Aaaft-0482-B] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Mr. Raghav Rajeev Menon, Advocate (Virtual) प्रत्यथी की ओर से/Respondent By : Mr. N. Rajakumar, Addl. Cit.

For Appellant: Mr. Raghav Rajeev Menon, AdvocateFor Respondent: Mr. N. Rajakumar, Addl. CIT

Section 143(3)Section 68

filed its return of income for the A.Y.2018-19 by declaring a total income of Rs.30,35,810/- on 28.11.2018. The case was selected for complete scrutiny and statutory notices were issued to the assessee and assessee filed the details called for. The AO found that the unsecured loan of Rs.1

Redseer Management Consulting Private Limited, Bengaluru vs. DCIT, Circle-5(1)(1), Bangalore

ITA 697/BANG/2025[2020-21]Status: DisposedITAT Bangalore02 Sept 2025AY 2020-21

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri Siddanna, CAFor Respondent: Shri Subramanian .S, JCIT-DR

Section 143(1)Section 143(2)Section 37Section 80G

return of income on 04/02/2021 which was duly processed u/s.143(1) of the Act. Subsequently, the case was selected for scrutiny under CASS for complete scrutiny. Statutory notices were issued u/s.143(2) and 142(1) and the assessee also filed their objections to the said notices and also furnished

S S Memorial Shikshan Samaj Sewa Sansthan, Etawah vs. ITO, Exemption Ward, Agra

In the result, the appeal is allowed for statistical purposes

ITA 220/AGR/2025[2016-17]Status: DisposedITAT Agra29 Aug 2025AY 2016-17

Bench: : Shri M. Balaganesh & Shri Sunil Kumar Singhassessment Year: 2016-17

Section 12ASection 249(3)Section 250

educational institution and is registered u/s. 12AA of the Act. It filed return of income showing nil taxable income. Case was selected for complete scrutiny under CASS ‘large profit or gains from business or profession in case of Trust’. The assessee vide e-response dated 20.12.2018 filed before the Assessing

Krishna Construction Company, Rewa vs. Dy Commissioner of Income Tax Circle, Katni

In the result, the appeal is allowed for statistical purposes

ITA 204/JAB/2025[2017-18]Status: DisposedITAT Jabalpur29 Aug 2025AY 2017-18

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Sapan Usrethe, AdvocateFor Respondent: Sh. Alok Bhura, Sr. DR

Section 144Section 194CSection 234BSection 234DSection 250Section 270ASection 271ASection 40

assessee firm declared net profit before interest and salary to partners at Rs.89,45,851.61/- i.e. @ 7.36%. The case was selected for complete scrutiny through CASS. On perusal of the profit & loss account, the ld. AO observed that the assessee had debited Rs.4,50,47,450/- under the head, ‘material

Bharath Yuva Sankshema Sangham, Eluru vs. Income-Tax Officer, Eluru

In the result, appeal filed by the assessee is allowed

ITA 160/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam29 Aug 2025AY 2018-19

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआईटीए. नं. / Ita No. 160/Viz/2025 निर्धारणवर्ा/ Assessment Year:2018-19) Bharath Yuva Sankshema Sangham V. Income Tax Officer 20B-7-21/1 Income Tax Office C/O. Ayyappa Medicals Eluru, West Godavari Andhra Pradesh Gandhi Nagar, Eluru West Godavari District – 534002 Andhra Pradesh [Pan:Aidpg1046K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri C. Subrahmanyam राजस्व का प्रतततितित्व/ Department Represented By : Dr. Aparna Villuri, Sr.Ar

Section 143(1)Section 143(2)Section 143(3)Section 154Section 250

Rs.3,91,78,119/- and debited an expense of Rs.1,07,47,871/- as contribution to recognized Provident Fund. The case was selected for Complete Scrutiny assessment under the E-assessment Scheme, 2019 on the following issues:- i. Excess Contribution to Provident Fund, Superannuation or Gratuity Fund. 5. During

DCIT Central Circle-06, New Delhi vs. Santosh Trust, New Delhi

ITA 1427/DEL/2023[2017-18]Status: DisposedITAT Delhi29 Aug 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Sh. Suresh K. Gupta, AdvFor Respondent: Sh. Mahesh Shah, CIT, DR

Section 12ASection 133(6)Section 142(1)Section 143(2)Section 143(3)Section 69ASection 80G(5)(iv)

assessee Trust filed its return of income on 21.08.2017 declaring income at Rs.nil. The case of the assessee was selected for complete scrutiny through CASS and notice therefore, under Section 143(2) of the Act was issued on 12.09.2018 followed by questionnaire under Section 142(1) dated 17.10.2019. Pursuant

Future First Info Services Private Ltd., Delhi vs. AO Circle-7(1), Delhi

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

ITA 672/DEL/2022[2017-18]Status: DisposedITAT Delhi29 Aug 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

Section 143(3)Section 270ASection 92D

technology enabled support services, filed its Income Tax Return (‘ITR’) on 22.11.2017 declaring income of Rs.32,03,55,990/-. The case was selected for complete scrutiny. During the relevant year, the appellant assessee has provided certain services to its Associated Enterprise (‘AE’); namely, Mercury Derivatives Trading Ltd., Mauritius, which

Pawan Agarwal, Faridabad vs. DCIT Circle=1, Faridabad

ITA 1579/DEL/2020[2012-12]Status: DisposedITAT Delhi29 Aug 2025AY 2012-12

Bench: SHRI ANUBHAV SHARMA (Judicial Member), SHRI AMITABH SHUKLA (Accountant Member)

For Appellant: Dr. Rakesh Gupta, Advocate &For Respondent: Ms Harpreet Kaur Hansra, Sr. DR

Section 133ASection 139Section 143(3)

filed by the appellant declaring income of Rs.5,40,470/- on 23.07.2012. Subsequently, the case was selected through CASS for complete scrutiny. The assessment u/s 143(3) was completed on 18.03.2015 at an assessed income of Rs.6,00,95,560/-. 3. Now what comes up is that there

Dev Anand Bhatt, Haldwani vs. DDIT/ADIT Intl Lkn, Lucknow

In the result, the appeal of the assessee is allowed

ITA 1/LKW/2025[2019-20]Status: DisposedITAT Lucknow28 Aug 2025AY 2019-20

Bench: Sh. Subhash Malguria & Sh. Nikhil Choudharya.Y. 2019-20 Dev Anand Bhatt, Dev Towers, Vs. Ddit/Adit, 1/251, Joshi Garden Nawabi Intl, Lucknow Road, Haldwani Pan:Anopb1987A (Appellant) (Respondent) Assessee By: Sh. Prashant Kacker, C.A. Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 16.07.2025 Date Of Pronouncement: 28.08.2025 O R D E R Per Nikhil Choudhary, A.M.: [ This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A)-2, Noida Under Section 250 Of The Income Tax Act, 1961, Dated 29.11.2024, Dismissing The Appeal Of The Assessee Against The Order Passed By The Ld. Ao, Under Section 143(3) R.W.S. 144C(3) Of The Income Tax Act On 28.04.2022. The Grounds Of Appeal Are As Under:- “I. On The Facts & Circumstances Of The Case & In Law The Learned Commissioner Of Income Tax (Appeals), Erred In Confirming The Addition In Order U/S 143(3) Read With Section 144C(3) Of The Act Amounting To 42,50,737.00 Against Facts & Law. Ii The Appellant Respectfully, Submits As Under:- 1. The Learned Commissioner Of Income Tax Appeals (Cit-A) Has Without Going Into The Facts & Not Relying On The Practicality Of The Case Has Not Observed That The Appellant Had Rightly Offered Income For Tax. 2. That The Order Is Bad In Law, Not In Agreement With Facts & Is Against The Principles Of Natural Justice. Iii. The Appellant Craves To Leave To Add, Alter, Amend, And/Or To Modify Any Grounds Of Appeal, If Necessary.”

For Appellant: Sh. Prashant Kacker, C.AFor Respondent: Sh. Amit Kumar, DR

Section 142ASection 143(3)Section 144C(3)Section 250

filed a return of income for the assessment year 2019-20, declaring a total income of Rs.74,02,660/- . The case was selected for complete scrutiny on account of substantial refund claimed by the assessee. During the course of assessment proceedings, the ld. AO found that the assessee

Kalpesh Dhanjibhai Makasana, Surendranagar vs. Pr. CIT, Ahmedabad-3, Ahmedabad

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

ITA 1231/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad28 Aug 2025AY 2020-21

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 143(2)Section 143(3)Section 14ASection 263Section 80GSection 80G(5)Section 80G(5)(vi)

officer is of the opinion to make further disallowances other than the “limited scrutiny” he ought to have obtained permission from Ld. CIT making complete scrutiny assessment which is not been done in this case. The Ld. Assessing Officer issued notice u/s 142(1) relating to the limited scrutiny assessment

Bhanwarlal Champalal Kanunga, Unjha vs. The Pr. CIT, Ahmedabad-3, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1040/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad28 Aug 2025AY 2020-21

Bench: Ms Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No. 1040/Ahd/2025 िनधा"रण वष" /Assessment Year : 2020-21 Bhanwarlal Champalal Kanunga, The Principal A-43, Old Gunj Bazar, बनाम/ Commissioner Of V/S. Apmc Market Yard, Income Tax, Main Line, Ahmedabad-3, Unjha-384170. Ahmedabad. (Gujarat) "थायी लेखा सं./Pan: Acmpk0172H अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Parmanand Khatri, Ar Revenue By : Shri Rignesh Das, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 31/07/2025 घोषणा की तारीख /Date Of Pronouncement: 28/08/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: ] ] This Appeal By The Assessee Is Directed Against The Revisional Order Dated 27.03.2025 Passed By The Principal Commissioner Of Income-Tax-3, Ahmedabad [Hereinafter Referred To As “Pcit”] Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], Whereby The Assessment Order Dated 23.09.2022 Passed Under Section 143(3) Read With Section 144B Bhanwarlal Champalal Kanunga. Vs. Pcit Assessment Year 2020-21

For Appellant: Shri Parmanand Khatri, ARFor Respondent: Shri Rignesh Das, CIT-DR

Section 142(1)Section 143(2)Section 143(3)Section 144BSection 263

declaring total income of Rs. 63,44,860 and showing exempt agricultural income of Rs. 1,16,77,688. The case was selected for complete scrutiny under CASS inter alia for verification of large agricultural income and substantial loans. Notice under section 143(2) was issued on 29.06.2021. Thereafter

Settyhalli Venkataramappa Venkateshappa, Kolar vs. Income Tax Officer, Ward-1, Kolar

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

ITA 217/BANG/2025[2018-19]Status: DisposedITAT Bangalore28 Aug 2025AY 2018-19

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2018-19

For Appellant: Shri R. Chandrashekar, Advocate

Section 133(6)Section 143(2)Section 143(3)Section 44ASection 68

appeal before us. 2. The assessee filed income tax return on 30.10.2018 at a total income of Rs.5,09,880 which was selected for complete scrutiny by issue of notice u/s. 143(2) on 23.9.2019. During the assessment proceedings several notices were issued to the assessee, but assessee only furnished

ACIT 7(1)(1), Mumbai vs. Longseal Machinery Pvt Ltd., Mumbai

ITA 5523/MUM/2024[2018-19]Status: DisposedITAT Mumbai28 Aug 2025AY 2018-19

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: NoneFor Respondent: Shri Rajesh Kumar Yadav, CIT DR

Section 143(3)

case are that assessee filed its return of income on 28.10.2018 reporting total income at nil. Case of the assessee was selected for complete scrutiny under the e-assessment scheme, 2019 on the following issues: i. Investments/advances/loans ii. business loss iii. verification of transactions. 3. 1. Statutory notices were issued