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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

ACIT, Circle-1(1), Rajkot vs. Gandhi Reality (India) Private Limited, Rajkot

In the result, the appeal of the Revenue is dismissed

ITA 110/RJT/2025[2018-19]Status: DisposedITAT Rajkot25 Aug 2025AY 2018-19

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm

For Appellant: Shri R. K. Doshi, Ld. ARFor Respondent: Shri Praveen Verma, Ld. CIT. (DR)
Section 142(1)Section 143(2)Section 143(3)Section 144BSection 230

company filed Return of Income on 30.10.2018, by declaring loss of Rs. 16,34,80,379/-. Subsequently, the assessee`s case was selected for complete scrutiny under CASS. Accordingly, a notice u/s 143(2) of the Income Tax Act, 1961, dated 22.09.2019, was issued and the same was duly served

Ajaykumar Mahadevbhai Patel, Vadodara vs. The ITO, Ward-1(2)(1) Previously Ward-1(2)(4), Vadodara

In the result, the appeal of the assessee is allowed

ITA 1197/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad25 Aug 2025AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal(Assessment Year:2017-18 Ajaykumar Mahadevbhai Patel, The Income Tax Officer, Vs. B-198, Shrenik Park, Ward 1(2)(1), Productivity Road, (Previously Ward-1(2)(4), Akota, Vadodara-390020. Vadodara.) [Pan :Aeppp2801 M] (Appellant) .. (Respondent) Appellant By : Shri Pb Parmar, Ar Respondent By: Shri Prateek Sharma, Cit. Dr Date Of Hearing 05.08.2025 Date Of Pronouncement 25.08.2025 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

For Appellant: Shri PB Parmar, ARFor Respondent: Shri Prateek Sharma, CIT. DR
Section 234ASection 271ASection 69A

appeal. 3. The assessee filed his return of income on 22.07.2017 declaring total income of ₹2,86,290/-. The case was selected for complete scrutiny under CASS on account of high cash receipts and abnormal increase in cash deposits during the year, including during the demonetisation period. During the assessment

Metso Oyj, Finland vs. Assistant Commissioner of Income Tax, (International Taxation), Circle-1(2), Kolkata

In the result, the appeal filed by the assessee is dismissed and the order of the Ld

ITA 616/KOL/2025[2022-23]Status: DisposedITAT Kolkata25 Aug 2025AY 2022-23

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 143(3)Section 144C(13)Section 144C(5)Section 234BSection 270ASection 56Section 9

filed by Metso Outotec OYJ on 29.11.2022 for the impugned assessment year showing total taxable income of ₹ ‘NIL’ which was selected for complete scrutiny under Computer Assisted Scrutiny Selection (in short 'CASS') on the issue of large refund claimed by non- resident. During the year under consideration the assessee

Mcleod Russel India Ltd., Kolkata vs. DCIT, Circle 4(1), Kolkata

In the result, the appeal of the assessee is partly allowed

ITA 384/KOL/2025[2020-21]Status: DisposedITAT Kolkata25 Aug 2025AY 2020-21

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(1)Section 144C(1)Section 14A

which a net loss of Rs. (-)27,98,93,120/- has been declared. The case was selected for complete scrutiny under CASS to examine and draft order u/s 144C(1) of the Act which was passed on 29.09.2023 proposing to assess the total income of the assessee company

Babita Sharma, Sonipat vs. Income Tax Officer, Ward-1, Sonipat

Appeal is allowed

ITA 4409/DEL/2025[2015-16]Status: DisposedITAT Delhi25 Aug 2025AY 2015-16

Bench: Sh. Satbeer Singh Godaraita No. 4409/Del/2025 : Asstt. Year : 2015-16 Babita Sharma, Vs Income Tax Officer, 582, Mission Road, Ward-1, Sonepat, Haryana-131001 Sonepat, Haryana-131001 (Appellant) (Respondent) Pan No. Cqeps0819R Assessee By: Sh. S. K. Jain, Adv. & Sh. Subodh Jain, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 25.08.2025 Date Of Pronouncement: 25.08.2025 Order This Assessee’S Appeal For Assessment Year 2015-16, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1074303204(1) Dated 10.03.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. S. K. Jain, Adv. &For Respondent: Sh. Manoj Kumar, Sr. DR
Section 143(2)Section 143(3)Section 147Section 48Section 54FSection 57

forward losses was inadmissible since the beginning itself and therefore the Assessing Officer was justified in disallowing the same without converting the case into complete scrutiny? 5. We have heard Mr. Amit Sharma, learned standing Counsel appearing for the appellant and Mr. Abhratosh Majumder, learned senior Advocate for the respondent ... limited scrutiny were beyond jurisdiction of the Assessing Officer as the scrutiny assessment was selected for limited scrutiny under Section 143(2) and not complete scrutiny. The Department objected to the additional ground which were raised by the appellant before the Tribunal. However, the learned Tribunal overruled the said objection

Shri Gaushala Baba Phulu Sadh, Jind, Haryana vs. ITO Ward-1, Jind, Haryana

Appeal is allowed

ITA 4320/DEL/2025[2016-17]Status: DisposedITAT Delhi25 Aug 2025AY 2016-17

Bench: Sh. Satbeer Singh Godaraita No. 4320/Del/2025 : Asstt. Year : 2016-17 Sh. Gaushala Baba Phulu Sadh, Vs Income Tax Officer, Uchana Khurd, Jind, Ward-1, Haryana-126102 Jind, Haryana-126102 (Appellant) (Respondent) Pan No. Aagts5155E Assessee By: Sh. Ashok Kumar Goyal, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 25.08.2025 Date Of Pronouncement: 25.08.2025 Order This Assessee’S Appeal For Assessment Year 2016-17, Arises Against The Addl./Jcit(A)-3, Mumbai’S Din & Order No. Itba/Apl/S/250/2025-26/1075626735(1) Dated 15.04.2025, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Ashok Kumar Goyal, CAFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 143(2)Section 143(3)Section 40A(3)Section 57

forward losses was inadmissible since the beginning itself and therefore the Assessing Officer was justified in disallowing the same without converting the case into complete scrutiny? 5. We have heard Mr. Amit Sharma, learned standing Counsel appearing for the appellant and Mr. Abhratosh Majumder, learned senior Advocate for the respondent ... limited scrutiny were beyond jurisdiction of the Assessing Officer as the scrutiny assessment was selected for limited scrutiny under Section 143(2) and not complete scrutiny. The Department objected to the additional ground which were raised by the appellant before the Tribunal. However, the learned Tribunal overruled the said objection

Trinetra Innovations Pvt. Ltd., Dhanbad vs. DCIT/ACIT, Circle, Dhanbad

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

ITA 369/RAN/2024[2020-21]Status: DisposedITAT Ranchi22 Aug 2025AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Ratnesh Nandan Sahayi.T.A. No. 369/Ran/2024 Assessment Year: 2020-2021 Trinetra Innovations Pvt. Limited,…………..Appellant Dhansar, S.O. Jharia, Dhanbad-828106, Jharkhand [Pan:Aabct8553H] -Vs.- Deputy Commissioner /Assistant Commissioner Of Income Tax,……………………………………..…...Respondent Circle-1, Dhanbad, Office Of The Dcit/Acit, Aayakar Bhawan, Luby Circular Road, Dhanbad-826001, Jharkhand Appearances By: N O N E, Appeared On Behalf Of The Assessee Shri Khubchand T. Pandya, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: July 21, 2025 Date Of Pronouncing The Order: August 25, 2025 O R D E R

Section 142(1)Section 270A

coal and coke as well as sale and purchase of land. The case of the assessee-company was selected for scrutiny under CASS for complete scrutiny. The assessee-company has claimed substantial business loss and set off the same against income under other heads. The assessee has shown wrong loss

Assistant Commissioner of Income Tax, Jalandhar vs. M/S Jasdeep Kaur Chadha, Jalandhar

In the result, the appeal of the assessee is allowed and the revenue appeal is dismissed

ITA 359/ASR/2025[2018-19]Status: DisposedITAT Amritsar22 Aug 2025AY 2018-19

Bench: Sh. Udayan Das Gupta & Sh. Khettra Mohan Roy

Section 143(3)Section 68

filed its return of income on 30.10.2018, declaring total income of Rs.4,35,17,680/-. Subsequently, the case of the assessee was selected for complete scrutiny and specific issues related to the ‘issuance of unsecured loan’ and ‘Business expenses’ was pointed out by Ld. AO. Thereafter, the AO passed

Jasdeep Kaur Chadha-Jalandhar, Punjab vs. Jao the DCIT Circle-4 Jalandhar, Punjab

In the result, the appeal of the assessee is allowed and the revenue appeal is dismissed

ITA 250/ASR/2025[2018-2019]Status: DisposedITAT Amritsar22 Aug 2025AY 2018-2019

Bench: Sh. Udayan Das Gupta & Sh. Khettra Mohan Roy

Section 143(3)Section 68

filed its return of income on 30.10.2018, declaring total income of Rs.4,35,17,680/-. Subsequently, the case of the assessee was selected for complete scrutiny and specific issues related to the ‘issuance of unsecured loan’ and ‘Business expenses’ was pointed out by Ld. AO. Thereafter, the AO passed

Satya Syamala Mangamamba, K.V.Ranga Reddy vs. ITO., Ward-9(1), Hyderabad

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

ITA 973/HYD/2025[2022-23]Status: DisposedITAT Hyderabad22 Aug 2025AY 2022-23

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, K. KulasekharFor Respondent: Sri Posu Babu Alli, Sr. AR
Section 139Section 142(1)Section 143(2)Section 144Section 44A

./2025 Rs.23,34,734/- u/sec.139 of the Income Tax Act, 1961 [in short “the Act”]. The case of the assessee has been selected for complete scrutiny under e-assessment scheme, 2019 on the issue of large turnover, but, books of accounts not audited u/sec.44AB of the Income

Goldman Sachs (India) Finance Private Limited, Mumbai vs. Assessment Unit, Income-Tax Department, New Delhi

In the result, the appeal by the assessee is partly allowed for statistical

ITA 6766/MUM/2024[AY 2021-22]Status: DisposedITAT Mumbai22 Aug 2025

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Madhur AgrawalFor Respondent: Ms. Neena Jeph, CIT-DR
Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(1)Section 144C(5)Section 253Section 32Section 37(1)

return of income on 15.03.2022, declaring a total income of Rs.301,29,64,840/-. The return filed by the assessee was selected for complete scrutiny through CASS, and statutory notices under section 143(2) and section 142(1) of the Act were issued and served on the assessee. Pursuant

Sarena Private Limited, Delhi vs. PCIT Central, Delhi-3, Delhi

ITA 2480/DEL/2024[2014-15]Status: DisposedITAT Delhi22 Aug 2025AY 2014-15

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Shri Ambareesha Agrawal, CA &For Respondent: Shri Mahesh Kumar, CIT-DR
Section 142(1)Section 143(1)Section 143(3)Section 147Section 263Section 263(1)

assessee is a private limited company whose return was processed u/s 143(1) of the Act and later was selected for complete scrutiny and assessment order u/s 143(3) of the Act was passed accepting the returned income. Consequently, on the alleged information from the Investigation Wing, Delhi, regarding

Sarena Private Limited, Delhi vs. Pr, CIT Centre Delhi-3, Delhi

ITA 2479/DEL/2024[2013-14]Status: DisposedITAT Delhi22 Aug 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Shri Ambareesha Agrawal, CA &For Respondent: Shri Mahesh Kumar, CIT-DR
Section 142(1)Section 143(1)Section 143(3)Section 147Section 263Section 263(1)

assessee is a private limited company whose return was processed u/s 143(1) of the Act and later was selected for complete scrutiny and assessment order u/s 143(3) of the Act was passed accepting the returned income. Consequently, on the alleged information from the Investigation Wing, Delhi, regarding

Shri Mallikarjun Credit Souharda Sahakari Limited, Benadi vs. The Principal Commissioner of Income Tax, Hubli

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

ITA 151/PAN/2025[2020-21]Status: DisposedITAT Panaji21 Aug 2025AY 2020-21

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.151/Pan/2025 (A.Y.2020-21 ) Shri Mallikarjun Credit Vs. Pr.Cit, Soudharda Sahakari Limited, C.R.Building, A/P Benadi, Taluka Chikodi, Navanagar, Belagavi-591215, Hubli-580025, Karnataka. Karnataka Pan .No.Aabas3055M (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 143(3)Section 263Section 80PSection 80P(2)(d)

facts in the assessment proceedings and accepted the claim. Whereas the AO has applied the mind and accepted the assessee’s submissions in the complete scrutiny in respect of interest income on deposits with the cooperative banks. We rely on the decision of the Honble High Court of Bombay

Bhikhalal Prahaladrai Agarwal HUF, Gandhidham vs. Assistant Commissioner of Income Tax, Gandhidham Circle, Gandhidham

ITA 780/RJT/2024[2016-17]Status: DisposedITAT Rajkot21 Aug 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.779&780/Rjt/2024 ("नधा"रण वष" / Assessment Years: 2011-12 & 2016-17) Bhikhalal Prahaladrai Agarwal- Vs. Assistant Commissioner Of Income Tax, Huf, Gandhidham Circle C/O. Sarda & Sarda, Sakar, 1St It Office, Plot No. 32, Sector No. 3, Near Floor, Dr. Radha-Krishnan Road, Iffco Colony, Gandhidham Opp. Rajkumar College Rajkot Gandhidham - 370201 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabha4638R (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 05/06/2025 Date Of Pronouncement : 21/08/2025

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10(38)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 68

assessee, before us, is an HUF and derives income from the business of transportation. The assessee`s case was taken up for complete scrutiny and a notice under section 143(2) of the Income tax Act, 1961, was issued on 03.07.2017 and was duly served upon through ITBA email facility

Bhikhalal Prahladrai Agarwal HUF, Gandhidham vs. Assistant Commissioner of Income Tax Gandhidham Circle, Gandhidham

ITA 779/RJT/2024[2011-12]Status: DisposedITAT Rajkot21 Aug 2025AY 2011-12

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.779&780/Rjt/2024 ("नधा"रण वष" / Assessment Years: 2011-12 & 2016-17) Bhikhalal Prahaladrai Agarwal- Vs. Assistant Commissioner Of Income Tax, Huf, Gandhidham Circle C/O. Sarda & Sarda, Sakar, 1St It Office, Plot No. 32, Sector No. 3, Near Floor, Dr. Radha-Krishnan Road, Iffco Colony, Gandhidham Opp. Rajkumar College Rajkot Gandhidham - 370201 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabha4638R (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 05/06/2025 Date Of Pronouncement : 21/08/2025

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10(38)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 68

assessee, before us, is an HUF and derives income from the business of transportation. The assessee`s case was taken up for complete scrutiny and a notice under section 143(2) of the Income tax Act, 1961, was issued on 03.07.2017 and was duly served upon through ITBA email facility

Hiralal Vijawat, Bhawanimandi vs. ACIT / DCIT Central Circle Kota, Kota

ITA 614/JPR/2025[2019-20]Status: DisposedITAT Jaipur21 Aug 2025AY 2019-20
For Appellant: Sh. Mahendra Gargieya, Adv. (VC)For Respondent: Sh. Gaurav Awasthi, JCIT, SR. DR
Section 133ASection 139Section 143(2)Section 143(3)Section 234BSection 69C

such additional income of Rs.71,00,003/- (i.e. 70 Lakhs plus 1 Lakh additional as cash in hand). Thereafter, the case was selected for complete Scrutiny assessment. The AO completed the impugned assessment u/s 143(3) vide order dated 30.09.2021, accepting the ROI filed by the assessee dt. 30.09.2021, without

Sequel Buildcon Pvt Ltd, Karkardooma Community Centre vs. DCIT, Central Circle-, New Delhi

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

ITA 1409/DEL/2025[2022-23]Status: DisposedITAT Delhi21 Aug 2025AY 2022-23

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwal

Section 115BSection 139(1)Section 142(1)Section 143(2)Section 143(3)Section 68

company is engaged in the business of real estate activities. The case of the assessee was selected for complete scrutiny through Computer Assisted Scrutiny Selection. Accordingly, notice u/s 143(2) and u/s 142(1) of the Act, were issued with questionnaire. The assessee filed their submission but not reply

The Belgaum Manufacturers Co-Op Industrial Estate Ltd, Belagavi vs. Pr. Commissioner of Income Tax, Hubbali

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

ITA 154/PAN/2025[2020-21]Status: DisposedITAT Panaji20 Aug 2025AY 2020-21

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. No.154/Pan/2025 (A.Y.2020-21) The Belgaum Manufactures Vs. Pr.Cit, Co-Op Industrial Estate C.R.Building, Limited, Navanagar, 10 342/690,Udyambag, Hubli-580025, Belgaum-590008, Karnataka. Karnataka Pan .No.Aaaat7254J (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Pramod Y Vaidya.Ar Revenue By Shri.Captain Pradeep Arya.Cit.Dr सुनवाई की तारीख/Date Of Hearing 14.08.2025 घोषणा की तारीख/Date Of 20.08.2025 Pronouncement Order Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The Pr. Commissioner Of Income Tax (Pr.Cit) Hubli Passed U/S 263 Of The Act. The Assesse Has Raised The Grounds Of Appeal Challenging The Revision Order Passed By The Pr.Cit Set Aside The Order Passed By The Assessing Officer. 2. The Brief Facts Of The Case Are That, The Assessee Is A Cooperative Society Registered Under Bombay Co-Operative

Section 143(2)Section 143(3)Section 263Section 80PSection 80P(2)(d)

reply on 15.07.2021 placed at page 5&6 of the paper book emphasizing that the AO has called for the details in respect of complete scrutiny under CASS to verify the issues of (i)Large “any other amount allowable as deduction” claimed in schedule BP of return (ii)High Liabilities ... action of the Pr. CIT is not acceptable. Whereas the AO has applied the mind and accepted the assessee’s submissions in the complete scrutiny in respect of interest income on deposits with the cooperative banks. We rely on the decision of the Honble High Court of Bombay

Mata Mahalaxmi Souharda Pattin Sahakari Niyamit, Karwar vs. Income Tax Officer, Ward - 1, Karwar

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

ITA 110/PAN/2025[2017-18]Status: DisposedITAT Panaji20 Aug 2025AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.110/Pan/2025 (A.Y.2017-18 ) Mata Mahalaxmi Soudharada Vs. Ito-Ward-1, Pattin Sahakari Niyamit, Santeri Krupa, H.No.496, 1 St Floor, Kanga Road, Opp:Syndicate Bank Habbuwada, Main Road,Karwar, Karwar-581306, North Kanara-581301, Karnataka. Karnataka. Pan .No.Aadam0337N (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

total income of Rs. Nil after claiming deduction of Rs.8,01,686/- u/sec 80P(2) of the Act. Subsequently the case was selected for complete scrutiny under CASS. Further notice u/sec143 (2) and u/sec 142(1) of the Act are issued calling for details in support of return of income