“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

Hargovind Motibhai Desai, Ahmedabad vs. ITO Ward 3(3)(8), Ahmedabad (Existing ITO Ward 3(3)(1), Ahmedabad)

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 2191/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad12 Aug 2025AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Prakash D Shah, ARFor Respondent: Shri BP Srivastava, Sr. DR

Section 143(2)Section 143(3)Section 68

issue of "Agricultural Income". However, the Assessing Officer made several additions unrelated to the limited scrutiny issue without seeking prior approval for conversion into complete scrutiny. The Ld. AR, in this regard, placed reliance on the decision of the Co- ordinate Bench in the case of Shri Rajnikanth S. Bhalavat ... competent authority for converting ITA Nos. 2190-2191/Ahd/2024 Hargovind M Desai Vs. ITO Asst. Years : 2015-16 & 2016-17 - 4– the case into complete scrutiny, as mandated under CBDT guidelines and the decision of Co-ordinate Bench in the case of Rajnikanth S. Bhalavat (supra). In view

Hargovind Motibhai Desai, Ahmedabad vs. ITO, Ward 3(3)(7), Ahmedabad (Existing ITO Ward 3(3)(1), Ahmedabad), Vejalpur

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 2190/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad12 Aug 2025AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Prakash D Shah, ARFor Respondent: Shri BP Srivastava, Sr. DR

Section 143(2)Section 143(3)Section 68

Cupid Diamonds Private Limited, Mumbai vs. Pricipal Commissioner of Income Tax-5, Mumbai

In the result, the appeal of the assessee is allowed

ITA 478/MUM/2025[2021-22]Status: DisposedITAT Mumbai11 Aug 2025AY 2021-22

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Shubhash Shetty & Shri Vinayaka RaoFor Respondent: Shri R.A. Dhyani, (CIT-DR)

Section 133(6)Section 143(3)Section 263Section 37Section 69C

present case, assessee had filed return of income on 23.02.2022 declaring total income of Rs.2,41,89,710/-. The case was selected for Complete Scrutiny for the reason that business Page 3 ITA No. 478/Mum/2025 A.Y. 2021-22 Cupid Diamonds Private Limited purchases need to be verified for their genuineness ... No.791 of 2021(Bom). Per contra, the ld.AR vehemently contested the revision order by claiming that assessee's case was selected for complete scrutiny for A.Y. 21-22 for verifying genuineness of business purchases and evaluation of low returned income in spite of large turnover from Gems and Jewellery business

Income Tax Officer, Ward-1(3), Hyderabad vs. Bhagyanagar India Limited, Secunderabad

In the result, the appeal of the Revenue is dismissed

ITA 1200/HYD/2019[2016-17]Status: DisposedITAT Hyderabad08 Aug 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1200/Hyd/2019 (निर्धारण वर्ा/Assessment Year:2016-17) Income Tax Officer, M/S. Bhagyanagar India Ward-1(3), Hyderabad. Vs. Limited, Hyderabad. Pan:Aaacb8963C (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K.C. Devdas, C.A. रधजस् व द्वधरध/Revenue By: Shri Narender Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 24/07/2025 घोर्णध की तधरीख/Pronouncement: 08/08/2025 आदेश/Order Per Madhusudan Sawdia, A.M. : This Appeal Is Filed By Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Hyderabad (“Ld. Cit(A)”), Dated 16.05.2019 For The A.Y. 2016-17. 2. The Revenue Has Raised The Following Grounds Of Appeal:

For Appellant: Shri K.C. Devdas, C.AFor Respondent: Shri Narender Kumar Naik

Section 115JSection 143(2)Section 143(3)Section 14ASection 37(1)Section 80

income, and reported book profit of Rs.1,78,69,216/- under Section 115JB of the Act. The case of the assessee was selected for complete scrutiny under CASS and accordingly, notice under Section 143(2) of the Act was issued to the assessee on 07.08.2017. The Learned Assessing Officer

V V Transport, Rohtak vs. Assistant Commissioner of Income Tax, Rohtak

In the result, the appeal of the assessee is allowed

ITA 989/DEL/2024[2017-18]Status: DisposedITAT Delhi08 Aug 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2017-18] V.V. Transport, Vs Acit, 96-A, Sindhu Bhawan, Rohtak Subhash Nagar, Rohtak, Haryana-124001. Pan-Aadfv5250G Appellant Respondent Appellant By Ms. Sakshi Pandey, Adv. Respondent By Shri Om Prakash, Sr. Dr Date Of Hearing 15.05.2025 Date Of Pronouncement 08.08.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 05.01.20248 Passed By Ld. Commissioner Of Income Tax (A)/Addl/Jcit(A)-7, Kolkata [“Ld.Cit(A)”] In Appeal No.Cit(A), Rohtak/10584/2019-20 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 20.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is A Partnership Firm, Engaged In The Business Of Running Of Petrol Pump. The Return Of Income For The Year Under Appeal Was Filed On 28.10.2017, Declaring Total Income Of Inr 4,29,25,730/-. The Case Of The Assessee Was Selected For Complete Scrutiny For The Reasons Of Cash Deposits During Demonetization Period & Notice U/S 143(2) Was Issued On 24.09.2018. After Considering The Submissions & The Books Of Accounts Submitted, The Ao Had Taken No Adverse Inference On The Issue Of Cash Deposited During Demonetization Period However, He Has Made Disallowance Of Inr 12,20,700/- By Holding That The Assessee Has Made Interest Free Advances To Staff & To One Of The Partners Whereas It Is Paying Interest On The Borrowings. In First Appeal, Ld.Cit(A) Has Deleted The Disallowance Made Out Of The Interest Payments Towards The Staff Advances Given However, Confirmed The Disallowance On Account Of Advances Given To The Partner Of Inr 1 Crore.

Section 143(2)Section 143(3)Section 234ASection 250Section 36

year under appeal was filed on 28.10.2017, declaring total income of INR 4,29,25,730/-. The case of the assessee was selected for complete scrutiny for the reasons of cash deposits during demonetization period and notice u/s 143(2) was issued on 24.09.2018. After considering the submissions

Children Welfare Trust (Regd), Faridabad vs. CIT Exemption, Chandigarh

In the result, Appeal of the Assessee is allowed

ITA 3637/DEL/2024[2016-17]Status: DisposedITAT Delhi08 Aug 2025AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 3637/Del/2024 (A.Y 2016-17) Children Welfare Trust (Regd) Vs National Faceless C/O. Gita Balniketan Senior Assessment Centre, Secondary School, 3-E, Nit, Delhi (Nafac) Faridabad Delhi Pan: Aabtc6957B Appellant Respondent Assessee By Sh. Pavan Ved, Adv, Shri Mohit Gupta, Ca, Sh. Mirza, Ca & Shri Sarthakkh Aggarwal, Ca Revenue By Ms.Pooja Swaroop, Cit(Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 08/08/2025

Section 11(6)Section 139Section 143(3)Section 147Section 148Section 263

income by claiming refund of Rs. 3,15,334/-. The case of the Assessee trust Children Welfare Trust Vs. CIT(E) was selected for ‘Complete Scrutiny’ and an assessment order came to be passed on 30/12/2018 u/s 143(3) of the Act by accepting the returned income. Thereafter the case ... heard both the parties and perused the material available on record. In the present case, the case of the Assessee has been selected for complete scrutiny and the assessment u/s 143(3) of the Act has been concluded on 30/12/2018, wherein the return income has been accepted by the DCIT

Joseph Jose, Patna vs. Dc/Ac, Circle-4, Patna

The appeal of the assessee is allowed for statistical purposes

ITA 197/PAT/2025[2017-18]Status: HeardITAT Patna07 Aug 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.197/Pat/2025 Assessment Year: 2017-18 Joseph Jose……………………….....…..…………………....Appellant House Of Sudhir Kr. Singh, Opposite Loyala High School, P.O Sadaqat, Ashram Kurji Patna, Bihar-800010. [Pan: Ajlpj6722E] Vs. Dc/Ac, Cir-4, Patna……….……….…............................…..…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 24, 2025 Date Of Pronouncing The Order : August 07, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Has Been Filed By The Assessee Against The Order Passed By The Cit, Appeal Addl/Jcit(A)-10, Delhi ["Cit(A)"] For The Assessment Year 2017-18. 2. Brief Facts Of The Case Ate That The Assessee Is An Individual & Derived His Income From House Property, Business & Other Sources For The Assessment Year 2017-18. The Assessee Filed His Return Of Income Declaring Total Income Of Rs.16,51,470/-. The Case Of The Assessee Was Selected For Complete Scrutiny Through Cass Showing Reason For Abnormal Increase In Cash Deposits During Demonetization Period As Compared To Pre-Demonetisation Period. Therefore, The Assessing Officer Issued Notices U/S 143(2) & 142(1) Of The Act Asking For Various Details.

Section 143(2)Section 69A

assessee filed his return of income declaring total income of Rs.16,51,470/-. The case of the assessee was selected for complete scrutiny through CASS showing reason for abnormal increase in cash deposits during demonetization period as compared to pre-demonetisation period. Therefore, the Assessing Officer issued notices

Shri Giriraj Ply N Board Industries Ltd., Ahmedabad vs. The ITO, Ward-2(1)(1) Now Ward-4(1)(1), Vadodara

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

ITA 1234/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad07 Aug 2025AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalshri Giriraj Ply N Board Income Tax Officer, Vs. Industries Ltd., Ward-2(1)(1), G-6, Word Business House, Vadodara. Near Parimal Garden, (Now Ward-4(1)(1)) Elis Bridge, Ahmedabad. Ahmedabad-380006. [Pan :Aabcg2319 Q] (Appellant) .. (Respondent) Appellant By : Shri Anil Kshatriya With Shri Alay Anil Kshatriya, Ars Respondent By: Shri Prateek Sharma, Sr. Dr Date Of Hearing 06.08.2025 Date Of Pronouncement 07.08.2025

For Appellant: Shri Anil Kshatriya with Shri Alay Anil Kshatriya, ARsFor Respondent: Shri Prateek Sharma, Sr. DR

Section 250Section 41(1)

however, the Shri Giriraj Ply N Board Industries Ltd Vs. ITO Asst. Year : 2016-17 - 2– A.O. has travelled beyond jurisdiction by converting into complete scrutiny by scrutinizing the other issue and making addition on account of remission of trade liability u/s.41(1) of the Act of Rs.26 ... made any addition in the hands of the appellant. (2) That when the assessment is made by the A.O. as complete scrutiny, there is not a whisper in the assessment order as to the prior permission of the PCIT having been obtained allowing the A.O. for conversion of limited scrutiny

Income Tax Officer -5(3)(1), Mumbai vs. Verve Industries Private Limited, Mumbai

In the result, appeal of the revenue is allowed in part for statistical purposes

ITA 4051/MUM/2025[2022-23]Status: DisposedITAT Mumbai07 Aug 2025AY 2022-23

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Mehul Tarela, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R

Section 133(6)Section 68

assessee engaged in the business of coal trading, handling and disposal of flyash and related activities. The return was selected for complete scrutiny under CASS and accordingly statutory notices were issued and served upon the assessee. While scrutinizing the return of income interalia, the AO noticed that the assessee

Abhishek Agrawal, Gwalior vs. Income Tax Officer, Ward 2(3), Gwalior

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

ITA 305/AGR/2025[2017-18]Status: DisposedITAT Agra06 Aug 2025AY 2017-18

Section 143(3)Section 250Section 69A

Income Tax Act, 1961 (hereinafter referred to 'the Act') dated 24.12.2019. 2. Brief facts of the case:- This case was selected for complete scrutiny for the reasons "cash deposits during the year”. The Assessing Officer noted that the assessee had deposited a sum of Rs.1,25,50,000/- during

Income Tax Officer, Gudiwada vs. Dandu Madhu Varma, Bhujabalapatnam

In the result appeal ITA

ITA 40/VIZ/2025[2022-23]Status: DisposedITAT Visakhapatnam06 Aug 2025AY 2022-23

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.

For Appellant: Smt. Hemalatha K, CAFor Respondent: Dr. Satyasai Rath, CIT-DR

Section 143(2)Section 143(3)Section 44A

verification of the Assessing Officer is to verify within the parameters laid down by the CBDT. Further, once the case is selected for complete scrutiny, the Assessing Officer can very well verify all the issues, even though, the notice has been issued for 8 ITA.Nos.129 & 40/Vizag/2025 one specific issue ... present case, whether the case has been selected for scrutiny for the purpose of limited verification of issues or it is a complete scrutiny. Although, the Counsel for the Assessee argued that, it is a limited scrutiny, but, failed to submit any evidence including relevant notice issued by the Assessing

Dandu Madhuvarma, Bhujapalapatnam vs. ITO, Ward-1, Gudivada

In the result appeal ITA

ITA 129/VIZ/2025[2022-23]Status: DisposedITAT Visakhapatnam06 Aug 2025AY 2022-23

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.

For Appellant: Smt. Hemalatha K, CAFor Respondent: Dr. Satyasai Rath, CIT-DR

Section 143(2)Section 143(3)Section 44A

Bheru Lal Kumawat, Vill Kulthana vs. ITO Pratapgarh, Pratapgarh

In the result, the appeal of the assessee is allowed

ITA 1288/JPR/2024[2016-17]Status: DisposedITAT Jaipur06 Aug 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Tarun Mittal, CAFor Respondent: Sh. Gautam Singh Choudhary, Addl. CIT

Section 143(2)Section 143(3)

other than recorded for limited scrutiny without following the procedure for conversion of limited scrutiny to the 3 Bheru Lal Kumawat vs. ITO fully complete scrutiny as prescribed by CBDT is bad in law and thus the consequent addition so made deserves to be deleted. 5.1. On the facts ... cannot be covered by scope of “Limited Scrutiny” and ld. AO has exceeded his jurisdiction in making such addition without converting Limited Scrutiny to Complete Scrutiny, which can be done only after seeking approval from designated authority. Apart from this, ld. AO by observing that as assessee is only

Vibrant Advertising Private Limited, Ahmedabad vs. Principal Commissioner of Income-Tax, Ahmedabad-3, Ahmedabad

In the result, the appeal of the assessee is allowed and the order passed under section 263 of the Act by the Principal CIT is quashed

ITA 1164/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad06 Aug 2025AY 2020-21

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Nimesh Vora, ARFor Respondent: Shri R P Rastogi, CIT-DR

Section 115BSection 135Section 143(3)Section 144BSection 263Section 800Section 80G

originally filed its return of income on 06.02.2021 declaring a total income of ₹14,16,80,730/-, and the case was selected for complete scrutiny under CASS. The assessment was completed under section 143(3) read with section 144B of the Act, accepting the return of income filed

Bioagile Therapeutics Private Limited, Bengaluru vs. Income Tax Officer, Ward-5(2)(1), Bangalore

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

ITA 376/BANG/2025[2018-19]Status: DisposedITAT Bangalore06 Aug 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Waseem Ahmedassessment Year : 2018-19

For Appellant: Smt. Pratibha R, Ld. Advocate

Section 143(3)Section 250Section 270ASection 270A(3)Section 80Section 80I

claimed deduction of Rs. 12,28,288/- u/s. 80IAC of the Act, by filing its original return of income which was selected for complete scrutiny and resulted into passing the assessment order, by which the Assessing Officer {AO} not only rejected such claim of the Assessee and but also initiated

Deputy Commissioner of Income Tax, Circle-3(1)(1), Bengaluru vs. Infosys Limited, Bengaluru

In the result, appeal filed by the assessee is partly allowed and the appeal filed by the revenue is dismissed

ITA 245/BANG/2024[2019-20]Status: DisposedITAT Bangalore06 Aug 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20

For Appellant: Sri Padam Chand Khincha – CAFor Respondent: Smt. Srinandini Das – CIT - DR

Section 1Section 10ASection 155Section 250

revised on 30- 11-2020 with total income of Rs. 12461,51,45,390/- Thereafter, the case of the assessee company was selected for complete scrutiny assessment under the E-assessment Scheme,2019. Accordingly, statutory notices u/s 143(2) as well as 142(1) of the Act were issued. After

Infosys Limited, Bangalore vs. Deputy Commissioner of Income-Tax, Circle-3(1)(1), Bangalore

ITA 881/BANG/2023[2019-20]Status: DisposedITAT Bangalore06 Aug 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Section 1Section 10ASection 155Section 250

again revised on 30- 11-2020 with total income of Rs.12461,51,45,390/-. Thereafter, the case of the assessee company was selected for complete scrutiny assessment under the E-assessment Scheme, 2019. Accordingly, statutory notices u/s 143(2) as well as 142(1) of the Act were issued. After

Tmt Employees Co Operative Credit Society Limited, Mumbai vs. Principal Commissioner of Income Tax -1, Thane

In the result, the appeal filed by the assessee bearing ITA

ITA 3591/MUM/2025[2020-21]Status: DisposedITAT Mumbai06 Aug 2025AY 2020-21

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankartmt Employees Co-Operative Vs Pcit, Thane-1 B Wing, Ashar It Park, 6Th Floor, Credit Society Ltd, Shop No.10, Prashaskiya Road No.16Z, Wagle Industrial Bhavan, Then M P (Tmt) Estate, Thane (West)-400 604 Employees Ccs, Wagle Estate, Wagle Aagar, Mumbai-400 604 Pan: Aaeat4545J Applicant Respondent

For Appellant: Shri Venugopal Nair, CAFor Respondent: Shri Ritesh Mishra, CIT DR

Section 143(1)Section 143(3)Section 144BSection 263Section 80PSection 80P(2)(d)

assessment year admitting taxable income at Nil. The return was processed under section 143(1) of the Act. Subsequently, the case was selected for complete scrutiny under CASS to verify – (i) High creditors / liabilities; and (ii) deduction from Total Income under Chapter VI-A. The Ld.AO issued notice and completed

Devinder Singh, Gurugram vs. ITO, Circle 1(1), Gurugram

In the result, appeal of the assessee is allowed

ITA 4782/DEL/2024[2018-19]Status: DisposedITAT Delhi06 Aug 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

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

Jay Prabhudas Vithalani, Jamnagar vs. Principal Commissioner of Income Tax, Jamnagar

In the result, both the appeals of the same assessee (ITA No

ITA 75/RJT/2025[2021-22]Status: DisposedITAT Rajkot05 Aug 2025AY 2021-22

Bench: Dr. Arjunlal Saini & Shri Dinesh Mohan Sinhaआयकर अपीलसं./Ita No. 75/Rjt/2025 (निर्धारणवर्ष / Assessment Year: (2021-22) (Hybrid Hearing) Jay Prabhudas Vithlani 201, Varajresidency, 8 – Patel Colony, Gujarat-361008 Vs. The Principal Commissioner Of Income Tax, Aayakar Bhavan, Nr. Subhash Bridge, Jamnagar Rajkot Highway Gujarat-361001 स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abcpv0266A (Appellant) (Respondent) आयकर अपीलसं./Ita No.74/Rjt/2025 (निर्धारणवर्ष / Assessment Year: (2021-22) Khushaboo Jaykumar Vithlani 201, Varajresidency, 8 – Patel Colony, Gujarat-361008 Vs. The Principal Commissioner Of Income Tax, Aayakar Bhavan, Lal Wadi Main Road, Kaushal Nagar, Gujarat - 361110 स्थायी लेखासं . / जी आइआरसं . / Pan/Gir.: Aefpv6723A (Appellant) (Respondent) Appellant By Respondent By Date Of Hearing Date Of Pronouncement : Shri Sagar Shah, Ld. Ar : Shri Sanjay Kumar, Ld. Cit(Dr) : 19/06/2025 : 05/08/2025 आदेश / Order Per Dinesh Mohan Sinha, Jm: Captioned Two Appeals Filed By The Different Assessee, Pertaining To Assessment Year (Ay) – 2021-22, Are Directed Against The Separate Order Passed By The Principal Commissioner Of Income Tax [(In Short "Ld. Pr.Cit”] U/S. 263 Of The Act, Both Orders Dated 24.01.2025. 2. Since, These Two Appeals Filed By The Different Assessee For Same

Section 263

Income for the AY under consideration was filed on 26/02/2022 declaring total income at Rs. 8,51,060/- This case was selected for Complete Scrutiny under CASS for the reasons that "Assessee has made substantial purchases from such suppliers who are either Non-Filer(s) or have filed non-business