“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

Khushboo Jaykumar Vithlani, Jamnagar vs. The Principal Commissioner of Income Tax, Jamnagar

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

ITA 74/RJT/2025[2021-22]Status: DisposedITAT Rajkot05 Aug 2025AY 2021-22

Bench: Dr. Arjunlal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 75/Rjt/2025 ("नधा"रणवष" / Assessment Year: (2021-22) (Hybrid Hearing) Jay Prabhudasvithlani Vs. The Principal Commissioner Of 201, Varajresidency, 8 – Patel Colony, Income Tax, Gujarat – 361008 Aayakar Bhavan, Nr. Subhash Bridge, Jamnagar Rajkot Highway Gujarat – 361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abcpv0266A (Appellant) (Respondent)

For Appellant: Shri Sagar Shah, Ld. ARFor Respondent: Shri Sanjay Kumar, Ld. CIT(DR)

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

Dr K R Shroff Foundation, Ahmedabad vs. The Dy. CIT, Circle-1, Exmp, Ahmedabad

Appeal of the assessee is partly allowed

ITA 769/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad05 Aug 2025AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Section 11Section 12ASection 143(3)Section 147Section 68

assessee had filed its return of income for the A.Y. 2018-19 on 26.10.2018 declaring income of Rs. Nil. The case was selected for complete scrutiny under CASS. The assessment was completed under Section 143(3) of the Act on 06.06.2022 at a total income of Rs.6

ACIT (Exemption) Circle 1 Ahmedabad, Ahmedabad vs. Dr K R Shroff Foundation, Ahmedabad

ITA 1205/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad05 Aug 2025AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Section 11Section 12ASection 143(3)Section 147Section 68

Sagarlaxmi Agriseeds Private Limited, Ahmedabad vs. The ACIT, Circle-4(1)(1), Ahmedabad

In the result, appeal of the assessee stands allowed

ITA 1918/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad05 Aug 2025AY 2017-18

Bench: S/Shri Sanjay Garg & Narendra Prasad Sinhaassessment Year : 2017-18 Sagarlaxmi Agriseeds Pvt Ltd Acit, Cir.4(1)(1) 206, Ashwamegh Avenue Vs Ahmedabad. Opp: Mithakhali Garden Navrangpura Ahmedabad. Pan : Aawcs 7561 F (Respondent) (Appellant) Assessee By : Shri Deepak R. Shah, Ar Revenue By : Shri Dharnidas V.S., Sr.Dr सुनवाई की तारीख/Date Of Hearing : 15/05/2025 घोषणा की तारीख /Date Of Pronouncement: 05/08/2025 आदेश/O R D E R

For Appellant: Shri Deepak R. Shah, ARFor Respondent: Shri Dharnidas V.S., Sr.DR

Section 143(1)Section 143(2)Section 143(3)Section 250Section 32

relevant parameters which formed the basis for selecting the case for scrutiny. However, in revenue potential cases, it was further provided that 'Complete Scrutiny' could be conducted, if there was potential escapement of income above a prescribed monetary limit, subject to the approval of administrative Pr. CIT/CIT/Pr. DIT/DIT. 2.In order ... ensure that maximum objectivity is maintained in converting a case falling under 'Limited Scrutiny’ into a 'Complete Scrutiny' case, the Sagarlaxmi Agriseeds Pvt.Ltd. vs. ACIT Asst.Year: 2017-18 11 matter has been further examined and in partial modification to Para 3(d) of the earlier order dated 29.12.2015, Board hereby

Eris Lifesciences Limited, Ahmedabad vs. The PCIT, Ahmedabad-1, Ahmedabad

Accordingly, the appeal of the assessee is also allowed for A

ITA 1038/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad04 Aug 2025AY 2021-22

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Biren Shah, ARFor Respondent: Shri R P Rastogi, CIT-DR

Section 143Section 143(3)Section 144BSection 14ASection 263

parties and perused all the relevant material available on record. It is pertinent to note that the Assessment Order was passed in respect of complete scrutiny assessment thereby the deduction claimed for Industrial Undertaking under Section 80IE was specifically called for as well as the expenses incurred for earning exempt

Eris Lifesciences Limited, Ahmedabad vs. The PCIT, Ahmedabad-1, Ahmedabad

Accordingly, the appeal of the assessee is also allowed for A

ITA 1037/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad04 Aug 2025AY 2020-21

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Biren Shah, ARFor Respondent: Shri R P Rastogi, CIT-DR

Section 143Section 143(3)Section 144BSection 14ASection 263

Prathamik Krushi Pattin Sahakar Sangh Niyamit Chimmad, Jamkhandi vs. Income Tax Officer, Ward-1, Bagalkot

ITA 286/BANG/2025[2018-19]Status: DisposedITAT Bangalore04 Aug 2025AY 2018-19

Bench: Shri Prashant Maharishi

For Appellant: Shri Ashok Mudnur, CAFor Respondent: Shri Ganesh R. Ghale, Standing Counsel for the Revenue

Section 143Section 80Section 80P

employee cooperative society engaged in the business of providing credit facilities to its members. The return of income was processed and was selected for complete scrutiny by issue of notice for verification of claim of deduction under section 80 P of the act. Necessary notices were issued, and the assessee

ACIT 2(2)(1) Mumbai, Aayakar Bhavan Mumbai vs. National Peroxide Limited, Mumbai

In the result, the appeal of the revenue bearing ITA No 2816/Mum/2023 is partly allowed

ITA 2816/MUM/2023[2018-19]Status: DisposedITAT Mumbai04 Aug 2025AY 2018-19

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeeacit 2(2)(1) Mumbai Vs National Peroxide Limited 4Th Floor, Naville House, J N Heredia Aayakar Bhavan M.K. Road, Mumbai-400 020 Marg, Ballard Estate, Mumbai-400 001 Pan: Aabcn7072K

For Appellant: Shri Yogesh TharFor Respondent: Shri Satyaprakash R Singh, CIT DR

Section 115Section 143Section 143(1)(a)Section 143(3)Section 14ASection 250Section 43B

that the assessee is engaged in the business of manufacturing and selling a chemical known as ‘Hydrogen Peroxide’. The case was selected for complete scrutiny under the Computer Aided Scrutiny Selection (CASS) and, accordingly, the assessment was completed under section 143(3) of the Act, determining the total income

Ravinder, Gurgaon vs. National Faceless Appeal Centre, Delhi

In the result, appeal of the assessee is allowed

ITA 4865/DEL/2024[2018-19]Status: DisposedITAT Delhi04 Aug 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2018-19

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 3 Ravinder v. NFAC A.Y. 2018-19 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 notice

Jelly Samkit Doshi, Sabarkantha vs. The ITO, Ward-1, Himatnagar

In the result the appeal of the assessee is dismissed

ITA 167/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad01 Aug 2025AY 2015-16

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2015-16 Jelly Samkit Doshi Ito, Ward-1 18, Mahavirnagar Society Vs. Himatnagar. Mahavirnagar, Himatnagar Sabarkantha-383 001. Pan : Bybps 4687 R (Applicant) (Responent) Assessee By : Shri Vipul Khandhar , Ar : Shri Amit Pratap Singh, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 29/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 01/08/2025

For Appellant: Shri Vipul Khandhar , AR

Section 10(38)Section 115BSection 142(1)Section 143(2)Section 250Section 68

individual who filed her return of income on 07.09.2015 2 declaring total income of Rs.6,21,190/-. The case was selected for complete scrutiny under CASS and notice under section 143(2) was issued on 28.07.2016 and duly served. Subsequent notices under section 142(1) along with questionnaires were also

Arup Banerji, Allahabad vs. Deputy Commissioner of Income Tax Circle-1, Allahabad

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

ITA 154/ALLD/2024[2015-16]Status: DisposedITAT Allahabad31 Jul 2025AY 2015-16

Bench: SH. SUBHASH MALGURIA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. S.K. Jaiswal, C.AFor Respondent: Sh. A.K. Singh, Sr. DR

Section 133(6)Section 143(3)Section 234BSection 250Section 43Section 43(5)Section 5

been conducted at his premises under section 133A on 17.12.2014, therefore, his case was a case that was to be taken up for complete scrutiny. Despite this, the ld. Sr. DR pointed out that the assessee did not submit a copy of the demat account or the copy

Satya Kumar Darbari, Lucknow vs. Dy.CIT Range-4, Lucknow

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

ITA 227/LKW/2023[AY 2015-16]Status: DisposedITAT Lucknow31 Jul 2025

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2015-16 Satya Kumar Darbari V. The Dcit 381, Rajendra Nagar Range 4 Lucknow Lucknow Tan/Pan:Agtpd4584H (Appellant) (Respondent) Appellant By: None Respondent By: Shri R. K. Agarwal, Cit(Dr) O R D E R

For Appellant: NoneFor Respondent: Shri R. K. Agarwal, CIT(DR)

Section 115BSection 143(3)Section 271(1)(c)Section 68

Rs.1,03,75,000/- by various entries without obtaining approval from prescribed Authority as per Board Circular No. 7/2014 dt. 4th March, 2014 for complete Scrutiny. 2. Because, the Ld. CIT (A) has erred on facts & law while sustaining the addition of Hon'ble Rs.1,03,75,000/-, ignoring

Shital Vipulkumar Dholakia, Ahmedabad vs. The Income Tax Officer, Ward-1(1)(3), Ahmedabad

ITA 259/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2021-22

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokar

For Appellant: Shri Tushar Hemani, Sr. Advocate andFor Respondent: Shri Sher Singh, CIT-DR

Section 133(6)Section 142(1)Section 143(3)Section 144BSection 250Section 40A(3)

income for A.Y. 2021–22 was filed by the assessee on 22.02.2022 declaring total income of Rs.29,29,810/-. The case was selected for complete scrutiny through Computer Aided Scrutiny Selection (CASS) on the grounds that the assessee has made substantial purchases from suppliers who are either non-filers

Shrisant Savtamali Gramin Bigarsheti Sahakari Patsanstha Maryadit, Ahilyanagar vs. Pr. CIT - 1, Pune

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

ITA 972/PUN/2025[2020-21]Status: DisposedITAT Pune31 Jul 2025AY 2020-21

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: CA Payal R. Rathi &For Respondent: Shri Amit Bobde

Section 143(1)Section 143(3)Section 263Section 37(1)Section 56Section 80PSection 80P(2)(a)Section 80P(4)

return was processed u/s 143(1) of the IT Act. Subsequently, the case was selected for complete scrutiny and the assessment was completed u/s 143(3) of the IT Act vide order dated 02.08.2022 accepting the income returned by the assessee. Subsequently, upon examining the assessment records, Ld. PCIT, Pune

Greenearth Resources and Projects Limited, Kolkata vs. National E Assessment Centre, Kolkata

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

ITA 2128/KOL/2024[2018-2019]Status: DisposedITAT Kolkata31 Jul 2025AY 2018-2019

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.2128/Kol/2024 Assessment Year: 2018-19 Greenearth Resources & Projects Ltd………………....Appellant Room No.866, Todi Corner, 8Th Floor, 32, Erza Street, Kol-1. [Pan: Aabcn1393B] Vs. National E-Assessment Centre, Kolkata….…..………………….…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri P. N. Barnwal, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 30, 2025 Date Of Pronouncing The Order : July 31, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre (Nfac), Dated 19.07.2024 Passed Under Section 250 Of The Income-Tax Act, 1961. 2. At The Outset, It Is Noted That There Is A Delay Of 32 Days In Filing The Present Appeal Before The Tribunal. The Assessee Has Filed A Condonation Petition Explaining The Reasons Or Such Delay. After Considering The Submissions & Materials On Record, We Are Satisfied That There Was Reasonable Cause For The Delay In Filing The Appeal. Accordingly, The Said Delay Is Condoned & The Appeal Is Admitted For Adjudication.

Section 143(2)Section 144Section 250Section 68

income was filed declaring a loss of ₹2,87,83,157/-, which was subsequently revised declaring the same amount. The case was selected for complete scrutiny under CASS, and notices under section 143(2) and 142(1) of the Income-tax Act, 1961 (“the Act”) were issued. However, there

Abm Knowledgeware Limited, Mumbai vs. Assessing Officer Circle 4(1)(1), Mumbai

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

ITA 3460/MUM/2025[2020-2021]Status: DisposedITAT Mumbai31 Jul 2025AY 2020-2021

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 135Section 142(1)Section 143(2)Section 143(3)Section 263Section 37Section 80G

issued to the assessee to verify large any claim of amount allowable as deduction under Schedule BP and the notice was issued for complete scrutiny. Scanned copy of the notice issued u/s.143(2) is as under: Notice under section 143(2) of the Income-tax Act, 1961 PAN: AAACE1259L Name ... preparing the return of income, there are certain issues, on which further clarification is required, therefore, return of income has been selected for complete scrutiny. किन मुद्दों पर प्रारम्भ में और स्पष्टीकरण की आवश्यकता है? What is/are the Issue(s) on which further clarification is required initially? S No Issue

Pashupati Capital Services Private Limited, Mumbai vs. Principal Commissioner of Income Tax Officer, Mumbai - 4, Mumbai

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

ITA 2985/MUM/2025[2020-21]Status: DisposedITAT Mumbai31 Jul 2025AY 2020-21

Bench: Shri Om Prakash Kant & Shri Raj Kumar Chauhan

Section 135Section 142(1)Section 143(2)Section 143(3)Section 263Section 28Section 37Section 37(1)Section 80G

other documents and submitted that as per income and loss determination proposal (ILDP) dated 13.12.2021, the case was selected for complete scrutiny assessment under CASS on the 4 grounds mentioned therein. Ld. DR referred to the statutory notice u/s 142(1) and also the assessment order where it is clearly ... stated that the case was selected for complete scrutiny, assessment under CASS on the following 4 issues mentioned in para 1 of the assessment order. It is therefore argued that it was not a limited scrutiny assessment but complete scrutiny assessment u/s 143(3) of the Act and notice

The Naval Dockyard Co Op Bank Limited, Mumbai vs. DCIT, Circle 1(3)(1), Mumbai

In the result, the appeal is accordingly allowed for statistical purposes in the above terms

ITA 4281/MUM/2024[2018-19]Status: DisposedITAT Mumbai31 Jul 2025AY 2018-19

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhanthe Naval Dockyard Co- Vs. Dcit Circle1(3)(1), Aayakar Bhavan, Op Bank Limited Mumbai-400 020 Shahid Bhagat Singh Road Fort, Mumbai-400 023 Pan/Gir No. Aabat7232R (Applicant) (Respondent) Assessee By Shri Jayesh Kala, Ld. Ar Revenue By Shri Leyaqat Ali Aafaqui, Sr. Dr Date Of Hearing 17.07.2025 Date Of Pronouncement 31.07.2025 आदेश / Order Per Raj Kumar Chauhan, Jm:

Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 250Section 43B

assessee also received a notice u/s 143(2) of the Act dated 21.09.2019 for AY 2018-19 as the case was selected complete scrutiny assessment under E-assessment Scheme, 2019 on the following issues:- i) Claim of any other amount allowable as deduction in Schedule BP ii) Refund Claim ... opportunity of hearing or show-cause notice to the assessee. Apart from that, it is seen that the assessee’s case was selected for complete scrutiny and in the assessment order passed u/s. 143(3), the returned income has been accepted. From the perusal of the assessment order

Alok Infrastructure Ltd, Mumbai vs. Principle Commissioner of Income Tax-6, Mumbai

In the result, appeal of the assessee is allowed

ITA 2628/MUM/2024[2017-18]Status: DisposedITAT Mumbai31 Jul 2025AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2017-18

For Appellant: Shri Nimesh Vora and Ms Moksha Mehta, AdvocatesFor Respondent: Shri Rajesh Kumar Yadav, CIT DR

Section 143Section 143(3)Section 144BSection 144B(1)(xxv)Section 144CSection 263Section 263(1)Section 92C

Section 144C but u/s.143(3A) and 143(3B). On perusal of this order, it is noted that case of the assessee was selected for complete scrutiny where one of the issues listed is international transactions. In the said draft order, there is no mention about the proposed upward TP adjustment ... this show cause notice. 4.1. Further, ld. PCIT while passing the impugned revisionary order observed that the case of the assessee was selected for complete scrutiny with international transaction being one of the issues involved. In para-5.1, ld. PCIT notes that the order passed by ld. Assessing Officer u/s.143

Joydeep Das, Pune vs. Deputy Commissioner of Income Tax, Circle (8), Pune

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

ITA 2336/PUN/2024[18-19]Status: DisposedITAT Pune30 Jul 2025

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Joydeep Das Dcit, Circle 8, Pune Flat No.L/505, Sapphire Park Chs Vs. Ltd., Park Street, Wakad, Pune – 411057 Pan: Alxpd5599D (Appellant) (Respondent) Assessee By : Shri Nikhil S. Pathak & Ms Arrchena Shetty Department By : Shri Ramnath P Murkunde Date Of Hearing : 29-07-2025 Date Of Pronouncement : 30-07-2025 O R D E R

For Appellant: Shri Nikhil S. Pathak and Ms Arrchena ShettyFor Respondent: Shri Ramnath P Murkunde

Section 17

leave encashment of Rs.1,27,718/- and gratuity amount of Rs.4,04,758/- which is exempt from tax. The case was selected for complete scrutiny assessment under the E-assessment Scheme, 2019 on the following issues: 2 S.No. Issues i. Salary Income ii. Refund Claim 3. During the course