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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

Amar Brothers Global P.Ltd, Kanpur vs. AO Circle-1(1), Kanpur

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

ITA 175/LKW/2024[2018-19]Status: DisposedITAT Lucknow29 Jul 2025AY 2018-19

Bench: Shri Kul Bharat & Shri Nikhil Choudharyआयकर अपील सं/ Ita No.175/Lkw/2024 ननिाारण वर्ा/ Assessment Year: 2018-19 Amar Brothers Global Pvt Ltd V. Dcit Circle-2(1)(1) 87/112, Kalpi Road, Kanpur- Vaibhav Bhawan, 802003. 15/295-A, Civil Lines, Kanpur-208001. Pan:Aaica6776A अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कक और से/Appellant By: Shri Rakesh Garg, Adv प्रत्यर्थी कक और से /Respondent By: Shri Amit Kumar, Cit(Dr) सुनवाई कक तारीख / Date Of Hearing: 02 07 2025 घोर्णा कक तारीख/ Date Of 29 07 2025 Pronouncement: आदेश / O R D E R

For Appellant: Shri Rakesh Garg, AdvFor Respondent: Shri Amit Kumar, CIT(DR)
Section 143(2)Section 143(3)Section 144BSection 14ASection 37

limited scrutiny and there being no approval obtained from the competent authority nor there being any order for converting the limited scrutiny to complete scrutiny, the assessment framed is bad in law and be quashed. Page 2 of 7 3. Because the assessment framed u/s 143(3) without following ... expenses claimed be allowed.” 2. The facts giving rise to the present appeal are that in this case, the case was selected for complete scrutiny assessment. A notice u/s 143(2) of the Income Tax Act, 1961 (“Act”, for short) was issued and served upon the assessee. The assessee

Kailashchandra Haumanprasad Sugla, Solapur vs. ITO, Ward-1(1), Solapur

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

ITA 1555/PUN/2025[2015-16]Status: DisposedITAT Pune29 Jul 2025AY 2015-16

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.1555/Pun/2025 िनधा"रण वष" / Assessment Year: 2015-16 Kailashchandra Haumanprasad V The Income Tax Officer, Sugla, S Ward-1(1), Solapur. 45/15, Samrat Chowk, Budhwar Peth, Prabhakar Nagar H/S, Solapur-413001. Maharashtra. Pan: Ahsps3244B Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte – Ar Revenue By Shri Sandeep P Sathe – Jcit(Dr) Date Of Hearing 16/07/2025 Date Of Pronouncement 29/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(Appeal)-3, Chennai Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16Dated 12.10.2023, Emanating From Order U/S.143(3) Of The Income Tax Act, 1961, Dated 26.12.2017. The Assessee Has Raised Following Grounds Of Appeal :

Section 143(3)Section 250Section 272A(1)(c)Section 41(1)Section 56(2)(vii)

CASS to verify the point of purchase of property, however learned Assessing officer has made various other additions without converting the same into a complete scrutiny and it appears that he has not obtained necessary sanction for same therefore assessment order passed is bad in law. Your appellant prays

Veerendra Basavaraj Koujalagi, Belagavi vs. PCIT Hubballi, Hubballi

ITA 103/PAN/2024[2018-2019]Status: DisposedITAT Panaji28 Jul 2025AY 2018-2019

Bench: Hon’Ble Shri Pavankumar Gadale & Shri G. D. Padmahshaliita Nos. 103/Pan/2024 Assessment Year : 2018-19 Veerendra Basavaraj Koujalagi C/O. Shri Laxmi Complex, Sadashiv Nagar, Belgavi-590001 Pan : Agrpk3086D . . . . . . . Appellant V/S The Pr. Commissioner Of Income Tax, Hubali. . . . . . . . Respondent Appearances Assessee By : Mr Shivanand Halbhavi [‘Ld. Ar’] Revenue By : Capt. Pradeep Arya [‘Ld. Dr’] Date Of Conclusive Hearing : 24/06/2025 Date Of Pronouncement : 28/07/2025 Order Per G. D. Padmahshali; The Assessee’S Captioned Appeal Impugns Din & Order 1063626985(1) Dt. 29/03/2024 Passed By Pr. Commissioner Of Income Tax, Hubali [‘Ld. Pcit’] U/S 263 Of The Income-Tax Act, 1961 [‘The Act’] Which Sought To Revise Order Of Assessment Dt. 26/04/2021 Passed U/S 143(3) R.W.S. 144B Of The Act By National Faceless E-Asstt. Centre, Delhi [‘Ld. Ao’] Anent To Assessment Year 2018-19 [‘Ay’].

For Appellant: Mr Shivanand Halbhavi [‘Ld. AR’]For Respondent: Capt. Pradeep Arya [‘Ld. DR’]
Section 143(1)Section 143(2)Section 143(3)Section 14ASection 263

present appeal loops round the powers of revisionary authority to revise an assessment order passed in pursuance of limited scrutiny assessment as against complete scrutiny. 3. Briefly stated facts born out of case records and as solidified by the rival parties are that; the assessee is a resident individual engaged ... issues mentioned in Limited Scrutiny. ⁠4. The learned PCIT is not justified in travelling beyond jurisdiction by converting into a Limited Scrutiny to Complete Scrutiny. 7. In the course of physical hearing, the Ld. AR Mr Halbhavi reiterated assessee’s solitary contention & submissions as were made in the revisionary ITAT

M/S.Mahogany Logistics Services Pvt. Ltd., Madurai vs. PCIT, Madurai-1

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

ITA 1631/CHNY/2024[2018-19]Status: DisposedITAT Chennai28 Jul 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1631/Chny/2024 िनधा"रण वष"/Assessment Year: 2018-19 M/S. Mahogany Logistics Services Vs. The Principal Commissioner Of Private Limited, Income Tax-1, 10, Jawahar Road, Chokkikulam, Madurai. Madurai 625 002. [Pan:Aafcd8781R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N.V. Balaji, Advocate ""थ" की ओर से/Respondent By : Shri S. Senthil Kumaran, Cit सुनवाई की तारीख/ Date Of Hearing : 30.04.2025 घोषणा की तारीख /Date Of Pronouncement : 28.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.03.2024 Passed By The Ld. Principal Commissioner Of Income Tax 1, Madurai Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short] For The Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Company [Earlier Known As M/S. Drsr Logistics Services Private Limited] Filed Its Return Of Income For The Ay 2018-19 Claiming Loss Of ₹.31,28,98,436/- Under 2

For Appellant: Shri N.V. Balaji, AdvocateFor Respondent: Shri S. Senthil Kumaran, CIT
Section 139(9)Section 143(3)Section 201Section 263Section 36Section 37Section 40

claiming loss of ₹.31,28,98,436/- under 2 I.T.A. No.1631/Chny/24 section 139(9) of the Act. The case was selected for complete scrutiny under CASS for the reason to verify the low income in comparison to high loans/investments in shares, lower amount of disallowance under section ... section 37(1) of the Act. He referred to the assessment order and submits that the Assessing Officer, inspite of selecting the case under complete scrutiny conducted only enquiries with reference to section 40(a)(ia) of the Act. He submits that the decision in the case of S.A. Builders