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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

Kaushal Pravinkumar Shah, Ahmedabad vs. The ITO, Ward-3(3)(2), Ahmedabad

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

ITA 885/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad20 Aug 2025AY 2017-18
Section 115BSection 142(1)Section 270ASection 69A

declaring income of Rs. 4,27,800/-, showing business income from trading in chemicals. The case was selected for complete scrutiny under CASS for the reason "large cash deposits during demonetisation period and business return filed for the first time.” During assessment proceedings, notices u/s 142(1) were issued calling

Mahadeo Ahilaji Vir, Pune vs. ACIT, NFAC, Pune

In the result, appeal of the assessee is allowed

ITA 1532/PUN/2025[2018-19]Status: DisposedITAT Pune20 Aug 2025AY 2018-19

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1532/Pun/2025 धििाारण वर्ा / Assessment Year: 2018-19 Mahadeo Ahilaji Vir, Vs Acit, Nfac, 469, Balaji Nagar, Pune Ganesh Nagar 2, Medankarwadi, Chakan Khed, Rajgurunagar, Pune-410501 Maharashtra Pan-Afdpv2328A Appellant Respondent

For Appellant: Shri Bhavesh Lodha &For Respondent: Shri Harshit Bari, Addl
Section 142(2)Section 143(3)Section 250

capital receipt. We observe that the assessee is an individual and return for A.Y. 2018-19 furnished on 31.08.2018. 7. Case selected for complete scrutiny followed by serving of valid notices u/s 142(2) and 142(1) of the Act. Ld. AO concluded the proceedings by observing that the assessee

Neotiss Private Limited, Medak vs. ACIT, Circle 8(1), Hyderabad

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

ITA 436/HYD/2023[2016-17]Status: DisposedITAT Hyderabad20 Aug 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.436/Hyd/2023 (निर्धारण वर्ा/Assessment Year: 2016-17) Neotiss Private Limited Vs. Acit Medak Circle-8(1) Pan : Aaacc8221G Hyderabad

For Appellant: Shri Sashank Dundu, ARFor Respondent: Shri Siva Prasad SV, DR
Section 142(1)Section 40

wants to assess any other income, then, the same can be considered after conversion of limited 8 Neotiss Pvt.Ltd. scrutiny into complete scrutiny with the approval of the competent authority. Since the AO made additions to other issues, which are different from the issues considered for limited scrutiny without

M/S. British Agro Products (India) Pvt. Ltd., Chennai vs. PCIT-1, Chennai

ITA 1146/CHNY/2025[2020-21]Status: DisposedITAT Chennai20 Aug 2025AY 2020-21

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1146/Chny/2025

Section 143(3)Section 263Section 36(1)(vii)Section 37

determining taxable loss at Rs.(-) 2,68,08,267/- after making addition of Rs.6,12,60,652/-. Pertinently, the case was selected in the complete scrutiny category. Among various issues enquired by the Ld.AO included an assessee's claim of write off of trade advance amounting to Rs.8

Vijaya Credit Co Operative Society Limited, Dakshina Kannada vs. Income Tax Officer, Ward-1, Puttur

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

ITA 2496/BANG/2024[2020-21]Status: DisposedITAT Bangalore20 Aug 2025AY 2020-21

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessment Year : 2020-21 Vijaya Credit Co-Operative Society Limited, The Income Tax Officer, Bantara Bhawana Building, Vs. Ward 1, Guruvayanakere, Belthangady Taluk, Puttur. Dakshina Kannada. 574 217. Pan: Aaajv 0583D Appellant Respondent Appellant By : Shri Tharun Kothari, Ca Respondent By : Shri Swaroop Mannava, Addl.Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 05.08.2025 Date Of Pronouncement : 20.08.2025 O R D E R Per Soundararajan Kthis Appeal Of The Assessee Is Filed Challenging The Order Of The Ld. Cit(Appeals), National Faceless Appeal Centre, Delhi (Nfac) Dated 23.10.2024 In Respect Of Assessment Year 2020-21. 2. The Brief Facts Are That The Assessee Is A Co-Operative Society Registered Under The Provisions Of Karnataka Co-Operative Societies Act. The Assessee Filed Return Of Income On 15.01.2021 Declaring An Income Of Rs.25,80,940. Thereafter Return Was Processed U/S. 143(1) Of The Income Tax Act, 1961 [The Act] By The Cpc. The Return Was Page 2 Of 3

For Appellant: Shri Tharun Kothari, CAFor Respondent: Shri Swaroop Mannava, Addl.CIT(DR)(ITAT), Bengaluru
Section 143(1)Section 143(2)Section 143(3)Section 250Section 80P(2)(a)

processed u/s. 143(1) of the Income Tax Act, 1961 [the Act] by the CPC. The return was Page 2 of 3 selected for complete scrutiny. Various notices u/s. 143(2) and 142(1) were issued to the assessee seeking particulars of high liability as compared to low income, large

Balvinder Singh, Karnal, Haryana vs. Income Tax Officer Ward-1, Karnal, Haryana

In the result, appeal of the assessee is allowed

ITA 4346/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Aug 2025AY 2018-19

Bench: SHRI SATBEER SINGH GODARA (Judicial Member)

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(viii)Section 57

declaring income of Rs. 6,35,470/-. His return was processed under section 143(1)(a) on 28.06.2019. His case was selected for complete scrutiny assessment under the e- assessment Scheme, 2019 on two issues, namely refund claim and winning from Lottery/crossword puzzle/horse races. The Ld. Assessing Officer ("AO") served

Leelu Ram, Gurugram vs. Income Tax Officer, Gurugam

In the result, appeal of the assessee is allowed

ITA 896/DEL/2024[2018-19]Status: DisposedITAT Delhi20 Aug 2025AY 2018-19

Bench: Shri Satbeer Singh Godaraassessment Year: 2018-19 Vs. Income Tax Officer, Sh. Leelu Ram, S/O-Mangal Singh, C/O-Ysr Gurugram & Associates, Plot No. 214, Basement, Sector-47, Haryana Pan: Apspr3189Q (Appellant) (Respondent) Assessee By Sh. M.R. Sahu, Ca Department By Sh. Manoj Kumar, Sr. Dr

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(viii)Section 57

return was processed under section 143(1)(a) on 28.06.2019. His case was 2 | P a g e selected for complete scrutiny assessment under the e- assessment Scheme, 2019 on two issues, namely refund claim and winning from Lottery/crossword puzzle/horse races. The Ld. Assessing Officer ("AO") served notice under section

Luxeva India Private Limited, Maharashtra vs. NFAC, Delhi

Appeal is allowed with aforesaid consequences to follow

ITA 4495/DEL/2024[2018-19]Status: DisposedITAT Delhi20 Aug 2025AY 2018-19

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Ms Neha Vikram, CA &For Respondent: Ms Amisha s. Gupt, CIT-DR
Section 142(1)Section 143(3)Section 56Section 56(2)(vii)Section 56(2)(viib)

declaring total income at Rs.Nil & current year loss of Rs. 11,80,83,348/-. The case was selected for Complete Scrutiny Assessment under the e-Assessment Scheme, 2019 to verify the issue of share premium & business loss. During the year under consideration, the appellant company allotted 1,98,885 shares

Income Tax Officer, C R Building Delhi vs. Spectra Televentures Private Limited, South Delhi

In the result, the appeal of the Revenue is dismissed

ITA 225/DEL/2024[2021-22]Status: DisposedITAT Delhi20 Aug 2025AY 2021-22

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2021-22] Ito, Vs Spectra Televentures Pvt.Ltd., Ward-24(1), B-170B, Gf, Khasra No.82, 83, C.R.Building, I.P.Estate, 84, 86, 91-94, Maidan Gari Delhi-110002. Extension, South Delhi, Delhi-110068. Pan-Aancs0303C Appellant Respondent Revenue By Shri Mahesh Kumar, Cit Dr Assessee By Ms. Rano Jain, Adv., Mansi Jain, Ca, Pranshu Singhal, Ca, Sakshi Rustagi, Adv. & Mudit Dewan, Adv. Date Of Hearing 27.05.2025 Date Of Pronouncement 20.08.2025 Order

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

year under appeal was filed on 27.01.2022, declaring total income of INR 48,13,760/-. The case of the assessee was selected for complete scrutiny for the reason “verification of genuineness of business purchases”. Thereafter, notice u/s 143(2) of the Act was issued on 08.07.2022 followed notice

Gaurav Singhal, New Delhi vs. ITO, Ward-17(4), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 3835/DEL/2019[2015-16]Status: DisposedITAT Delhi20 Aug 2025AY 2015-16

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2015-16 Gaurav Singhal, Vs. Income Tax Officer, 149, Tarun Enclave, Ward 17(4), C.R. Building, Pitampura, New Delhi New Delhi-1100 02 Pin: 1100 34 Aohps3787D (Appellant) (Respondent)

For Appellant: Shri R R Singhla, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 115BSection 127Section 142(1)Section 142(2)Section 143(2)Section 143(3)Section 250Section 68

Brief facts of case are that on 30.01.2016, assessee filed his return of income at Rs.5,34,400/-. The case was selected for complete scrutiny through CASS. Notice under Section 143(2) of the Act dated 29.07.2016 was issued by ITO, Ward 40(1), Delhi. Notice under Section

Dr. Om Prakash, Delhi vs. ACIT, Circle- 2, Ghaziabad

In the result, the appeal of the assessee is allowed

ITA 402/DEL/2018[2014-15]Status: DisposedITAT Delhi20 Aug 2025AY 2014-15

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2014-15 Dr. Om Prakash, Vs. Acit, C/O. Kapil Goel, Adv. Circle-2. F-26/124, Sector 7 Rohini, Ghaziabad Delhi-1100 85 Pan: Aecpp6941B (Appellant) (Respondent)

For Appellant: Dr. Kapil Goel, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 250Section 264

circumstances of the case and in law, ld CIT-A erred in not appreciating that limited scrutiny was vaguely and wrongly converted to complete scrutiny without following due process of law and extant CBDT instructions thus rendering additions beyond limited scrutiny as bad in law. 3 8. That

M. K. Enterprises, Jalandhar vs. Income Tax Officer Ward-3(5), Jalandhar

ITA 351/ASR/2023[2017-18]Status: DisposedITAT Amritsar19 Aug 2025AY 2017-18

Bench: Udayan Das Gupta & Shri Brajesh Kumar Singh[Assessment Year: 2017-18]

Section 144Section 68Section 69A

Income Tax Act, 1961, ignoring the facts and circumstances of the case.” 3. Brief facts of the case:- This case was selected for complete scrutiny under CASS for the reason of “Large cash deposited during demonetization period and abnormal increase in sales with decrease in profitability compared to preceding previous

Markandeya Co-Operative Credit Society Limited, Belagavi vs. The Income Tax Officer, Ward - 2, Belagavi

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

ITA 148/PAN/2025[2017-18]Status: DisposedITAT Panaji19 Aug 2025AY 2017-18

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member), SHRI G D PADMAHSHALI (Accountant Member)

disclosing a total income of Rs.Nil after claiming deduction of Rs.26,57,241/- u/sec 80P of the Act. Subsequently the case was selected for complete scrutiny under CASS to verify (i)Investments in shares/Advances/Loans and (ii) Deduction Under Chapter VIA. Further notice u/sec143 (2) and u/sec

The Sankeshwar Souhard Credit Sahakari Limited, Sankeshwar vs. The Pr. Commissioner of Income Tax, Hubli

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

ITA 118/PAN/2025[2020-21]Status: DisposedITAT Panaji19 Aug 2025AY 2020-21

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.118/Pan/2025 (A.Y.2020-21 ) The Sankeshwar Souhard Vs. Pr.Cit, Credit Sahakari Ltd, C.R.Building, Cts.No.41443/B/234, Navanagar, Near Hanuman Temple, Hubli-580025, Nidasoshi Road, Karnataka Sankeshwar-591313, Karnataka. Pan .No.Aaaat8125C (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

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

claim of deduction. The Ld. AR referred to the assessment order emphasizing that the AO has called for the details in respect of complete scrutiny under CASS to verify the issues of (i) Deduction from total income under chapterVIA.(ii)HighCreditors/Liabilities(iii)Investments/Adv ances/Loans and (iv) High interest expenditure/Finance costs ... 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

Indian Metals and Ferro Alloys Ltd, Bhubaneswar vs. DCIT, Circle-1(1), Bhubaneswar

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

ITA 506/CTK/2024[2021-22]Status: DisposedITAT Cuttack19 Aug 2025AY 2021-22

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 143(1)Section 143(2)Section 143(3)Section 144C(5)Section 234BSection 234CSection 270ASection 92CSection 92D

processed u/s.143(1) of the Act by the CPC on 14.11.2022 determining taxable income at ₹131,72,49,344/-. The case was selected for complete scrutiny through Computer Assisted Scrutiny Selection (in short 'CASS') for the reasons being large specified domestic transaction(s) and large aggregate value of specified domestic

Peeyush Agarwal, Jaipur, Rajasthan vs. ITO, Ward 1(5), Jaipur, Rajasthan

In the result Ground and 1 and 2 raised by the assessee are allowed

ITA 488/JPR/2025[2017-18]Status: DisposedITAT Jaipur19 Aug 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Vijay Goyal, C.A. &For Respondent: Mrs. Alka Gautam, CIT
Section 115BSection 143(2)Section 143(3)Section 145(3)Section 250Section 68Section 69A

report and audited Profit and Loss Account and Balance sheet at PB 5 to 34. The case of the assessee was taken up for complete scrutiny through CASS. The AO issued notices u/s 143(2) and 142(1) of the Act, from time to time which were served upon

Pannu Bhansali, Jodhpur vs. ACIT, Circle, Jodhpur

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

ITA 164/JODH/2024[2017-18]Status: DisposedITAT Jodhpur18 Aug 2025AY 2017-18

Bench: The Time Of Hearing.

For Appellant: Shri Amit Kothari, C.AFor Respondent: Smt. Anuradha, Addl. CIT DR
Section 115BSection 144Section 145(3)Section 69A

assessment year under consideration, the assessee filed her return of income declaring total income of Rs.53,21,050/-. The return was selected for complete scrutiny under the Computer Aided Scrutiny Selection (CASS) mechanism. Statutory notices under sections 143(2) and 142(1) of the Act were issued by the Assessing

Vikram Khanna, Amritsar vs. ITO, Income Tax Department

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

ITA 19/ASR/2024[2017-18]Status: DisposedITAT Amritsar18 Aug 2025AY 2017-18

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Kundan Pandey
Section 143(3)Section 250

Mandi, Amritsar. The return of income filed by the assessee disclosing a total income of Rs.7,34,840/- has been selected for complete scrutiny under CASS. In course of scrutiny replies were filed by the assessee along with the cash book of Vikram Enterprises, by the help of which

Komal Adlakha, Gurugram vs. ITO, Ward 2(2), Gurugram

In the result, appeal of the assessee is allowed

ITA 3652/DEL/2025[2019-20]Status: DisposedITAT Delhi18 Aug 2025AY 2019-20

Bench: Shri Satbeer Singh Godaraassessment Year: 2019-20 Vs. Ito, Komal Adlakha, A06, Parsvnath Green Ville, Ward-2(2), Sohna Road, Gurgaon Gurgaon Pan: Autpa5180C (Appellant) (Respondent) Assessee By Sh. Mahfuzur Rahman, Ca Department By Sh. Manoj Kumar, Sr. Dr

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

declaring income of Rs. 6,35,470/-. His return was processed under section 143(1)(a) on 28.06.2019. His case was selected for complete scrutiny assessment under the e- assessment Scheme, 2019 on two issues, namely refund 2 | P a g e claim and winning from Lottery/crossword puzzle/horse races

DCIT Central Circle-20, New Delhi vs. Bright Point India Pvt. Ltd., New Delhi

In the result, the appeal filed by the Revenue is dismissed

ITA 1697/DEL/2023[2017-18]Status: DisposedITAT Delhi18 Aug 2025AY 2017-18

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S.RIFAUR RAHMAN (Accountant Member)

For Appellant: Shri Ritik, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 114Section 143(2)Section 143(3)Section 37(1)

return of income for AY 2017-18 on 29.11.2017 declared loss from the business at Rs.9,70,47,842/-. The case was selected for complete scrutiny under CASS. Subsequently, notices under section 143(2) and 142(1) of the 2 Income-tax Act, 1961 (for short ‘the Act’) were issued