“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

Late. Mohammad Afzaluddin Quraishi Represented by Legal Representative (Lr) Mohammad Masihuddin Qu, Hyderabad vs. Income Tax Officer, Ward-8(2), Hyderabad

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

ITA 331/HYD/2025[2017-18]Status: DisposedITAT Hyderabad25 Jul 2025AY 2017-18

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: Shri T. Chaitanya Kumar, AdvocateFor Respondent: Shri Gurpreet Singh, Sr. AR

Section 69A

assessment year 2017-2018 on 07.11.2017, declaring total income of Rs.6,30,310/-. The case of the assessee has been selected for Complete Scrutiny under "CASS" to verify the cash deposits during the year under consideration. During the course of assessment proceedings, the Assessing Officer noticed that, the assessee

Asst. Commissioner of Income Tax, Circle-9(1), Hyderabad vs. Vedula Venkata Ramana, Hyderabad

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

ITA 1555/HYD/2017[2014-15]Status: DisposedITAT Hyderabad25 Jul 2025AY 2014-15

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.1555/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2014-15) Acit Vs. Shri Vedula Venkata Circle 9 (1) Ramana, Hyderabad Hyderabad Pan:Abhpv1213E (Appellant) (Respondent) राज" व "ारा/Revenue By:: Shri Narender Kumar Naik, Cit (Dr) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca सुनवाई की तारीख/Date Of Hearing: 30/06/2025 & 18/07/2025 घोषणा की तारीख/Pronouncement: 25/07/2025 आदेश/Order

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri Narender Kumar Naik, CIT (DR)

decided to convert the limited scrutiny to Page 3 of 11 ITA No 1555 of 2017 VedITA No 1555 of 2017 Vedula Venkata Ramana complete scrutiny and sought the permission from the Pr. CIT vide letter dated 14/12/2016 which was granted vide order dated 22/12/2016. The learned DR has submitted ... cash deposit in the Bank Account is very much subject matter of scrutiny itself selected under CASS, then the conversion of limited scrutiny to complete scrutiny by the Assessing Officer does not affect the validity of the addition made by the Assessing Officer due to some technical reason of show

Mohammed Gyasuddin, Kolkata vs. ITO, Ward 30(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1053/KOL/2025[2017-2018]Status: DisposedITAT Kolkata25 Jul 2025AY 2017-2018

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyi.T.A. No. 1053/Kol/2025 Assessment Year: 2017-2018 Mohammed Gyasuddin,…………………………Appellant 3, Dent Mission Road, Kolkata-700023, West Bengal [Pan:Afvpg2465H] -Vs.- Income Tax Officer,……………….……….....Respondent Ward-30(2), Kolkata, Aayakar Bhawan, Dakshin, 2, Gariahat Road, Kolkata-700031 Appearances By: Shri Miraj D. Shah, A.R., Appeared On Behalf Of The Assessee Shri Abhijit Adhikari, Jcit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: July 22, 2025 Date Of Pronouncing The Order: July 25, 2025 O R D E R

Section 139(1)Section 143(2)Section 143(3)Section 40A(3)

widespread manner from this financial year. 2. The three formats of notice(s) are: (i)Limited Scrutiny (Computer Aided Scrutiny Selection) (ii) Complete Scrutiny (Computer Aided Scrutiny Selection) (iii) Compulsory Manual Scrutiny The revised format of 143(2) notice(s) with a note on benefits & Procedures of 'EProceeding' facility ... 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? 6 Mohammed Gyasuddin These questions have been decided in favour of the assessee and against the revenue. The Hon'ble High Court concurred with

B. Arunkumar Capital & Credit Services Pvt Ltd, Mumbai vs. Principal Commissioner of Income Tax 3, Mumbai

In the result the appeal filed by the assessee stands partly

ITA 2034/MUM/2025[2020-21]Status: DisposedITAT Mumbai25 Jul 2025AY 2020-21

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

Section 143(1)Section 143(3)Section 263Section 37(1)Section 80G

submitted that, the assessing officer was under mandate to verify the issue pertaining to unsecured loans though the case of assessee was selected for complete scrutiny. He placed reliance on the notice issued u/s.143(2) of the Act at page 50-51 of the paper book. Referring to page ... Officer, National Faceless Assessment Centre, Delhi 5. 4. Further the assessment order also acknowledges the fact that the assessment was picked up for complete scrutiny only to verify large squared up loans during the year. He placed reliance on the following observations on coordinate bench of this Tribunal in case

Esscon Integrated Security Solutions Pvt Ltd, Delhi vs. ITO Ward-8(1), Delhi

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

ITA 162/DEL/2025[2020-21]Status: DisposedITAT Delhi25 Jul 2025AY 2020-21

Bench: Him :-

Section 143(2)Section 270ASection 272

case of the assessee was selected for scrutiny under CASS for complete scrutiny. In the response of notice issued, the assessee has not furnished any reply. Th AO completed the assessment and assessed the income of the assessee Rs. 75,26,448/- after making the additions. 4. Aggrieved the order

Amit Gupta, Delhi vs. ITO, Ward 35(1), Delhi

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

ITA 5480/DEL/2024[2021-22]Status: DisposedITAT Delhi25 Jul 2025AY 2021-22

Bench: the Ld. NFAC who vide order dated 23-08-2024 dismissed the appeal against which the assessee is in appeal before the tribunal.

Section 270Section 69C

that the assessee has filed his return of income for the A.Y.2021-22 on 05.03.2022 declaring total income at Rs.459870/-. The case was selected for complete scrutiny under CASS on the issue of “Business Purchase”. The assessee has not made A.Y. 2021-22 Amit Gupta vs. ITO 3 the compliance

Amit Gupta, Delhi vs. ITO Ward - 36(1), Delhi

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

ITA 5479/DEL/2024[2021-22]Status: DisposedITAT Delhi25 Jul 2025AY 2021-22

Bench: the Ld. NFAC who vide order dated 23-08-2024 dismissed the appeal being treated time barred. Being aggrieved the order of the Ld. NFAC the assessee filed this appeal before the tribunal.

Section 144BSection 69C

Maleckunnel Philip Varghese, Sambalpur vs. The Deputy Commissioner of Income Tax, Central Circle, Sambalpur

In the result, all the three appeals of the assessee are allowed

ITA 260/CTK/2025[2017-18]Status: DisposedITAT Cuttack24 Jul 2025AY 2017-18

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.257/Ctk/2025 आयकर अपील सं/Ita No.259/Ctk/2025 आयकर अपील सं/Ita No.260/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2017-2018) Maleckunnel Philip Varghese Vs Dcit, Central Circle, Sambalpur At/Po/Ps: Ainthapali, Dist : Sambalpur-768004 Pan No. :Abvpv 8418 K (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Sh P.K.Mishra & Baidyanath Behera, Ars राजस्व की ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 24/07/2025 घोषणा की तारीख/Date Of Pronouncement : 24/07/2025

For Appellant: Sh P.K.Mishra & Baidyanath Behera, ARsFor Respondent: Shri Ashim Kumar Chakraborty, CIT-DR

Section 132Section 133ASection 139(1)Section 142(1)Section 143(2)Section 143(3)Section 144Section 153B(1)(b)Section 153C

issued upon the assessee fixing the case on 14.08.2018 which were duly served upon the assessee. In the meantime, the case is selected or complete scrutiny as per Computer Aided Scrutiny Selection (CASS) hence, same is merged being assessment for A.Y 2017-18 has already been invoked as per proviso

Maleckunnel Philip Varghese, Sambalpur vs. The Deputy Commissioner of Income Tax, Central Circle, Sambalpur

In the result, all the three appeals of the assessee are allowed

ITA 259/CTK/2025[2017-18]Status: DisposedITAT Cuttack24 Jul 2025AY 2017-18

For Appellant: Sh P.K.Mishra & Baidyanath Behera, ARsFor Respondent: Shri Ashim Kumar Chakraborty, CIT-DR

Section 132Section 133ASection 139(1)Section 142(1)Section 143(2)Section 143(3)Section 144Section 153B(1)(b)Section 153C

Maleckunnel Philip Varghese, Sambalpur vs. The Deputy Commissioner of Income Tax, Central Circle, Sambalpur

In the result, all the three appeals of the assessee are allowed

ITA 257/CTK/2025[2017-18]Status: DisposedITAT Cuttack24 Jul 2025AY 2017-18

For Appellant: Sh P.K.Mishra & Baidyanath Behera, ARsFor Respondent: Shri Ashim Kumar Chakraborty, CIT-DR

Section 132Section 133ASection 139(1)Section 142(1)Section 143(2)Section 143(3)Section 144Section 153B(1)(b)Section 153C

Income Tax Officer, Sikar vs. Bhaskar Chauhan, Jaipur

In the result the appeal of the revenue in ITA no

ITA 868/JPR/2024[2017-18]Status: DisposedITAT Jaipur24 Jul 2025AY 2017-18

Bench: Him.

For Appellant: Shri S.L.Poddar, AdvFor Respondent: Mrs Alka Gautam, CIT-DR a

Section 143(3)Section 144Section 153CSection 251Section 69Section 69ASection 69C

Bhaskar Chouhan, Jaipur vs. Income Tax Officer, Sikar

ITA 533/JPR/2024[2017-18]Status: DisposedITAT Jaipur24 Jul 2025AY 2017-18

For Appellant: Shri S.L.Poddar, AdvFor Respondent: Mrs Alka Gautam, CIT-DR

Section 143(3)Section 144Section 153CSection 251Section 69Section 69ASection 69C

case are that the assessee filed his ITR on 07.11.2017 declaring total income of Rs.3,81,510/-. The case was selected for complete scrutiny u/s 143(3) under CASS and notice u/s 143(2) was issued on 24.09.2018 duly served upon the assessee. A specific information was received from ... this case, the assessee filed his ITR on 07.11.2017 vide ask No.293773461071117 declaring total income of Rs.3,81,510/-. The case was selected for complete scrutiny u/s 143(3) under CASS, and notice u/s 143(2) was issued on 24.09.2018 duly served upon the assessee. A specific information was received

Aa520 Veerampalayam Pacs Ltd., Erode vs. ITO, Ward-2(1), Erode

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

ITA 593/CHNY/2025[2020-21]Status: DisposedITAT Chennai24 Jul 2025AY 2020-21

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:593/Chny/2025 िनधा"रण वष" / Assessment Year: 2020-21 Aa520 Veerappampalayam Ito, Primary Agricultural Co-Operative Vs. Ward -2 (1), Society Ltd., Erode. 1, Aa520, Veerappampalayam, Veerappampalayam Bo, Attavanai Hanumanpalli, Erode – 638 101. [Pan:Aadaa-8893-M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Ms. G. Vardini Karthik, Advocate ""थ" की ओर से/Respondent By : Shri. Kumar Chandan, Jcit (Virtual)

For Appellant: Ms. G. Vardini Karthik, AdvocateFor Respondent: Shri. Kumar Chandan, JCIT (Virtual)

Section 119(2)(b)Section 139(1)Section 139(4)Section 2(6)Section 80PSection 80P(2)(a)Section 80P(2)(d)

declaring Gross total income of Rs.42,23,180/- by claiming the entire amount as deduction u/s.80P of the Act. The case was selected for complete scrutiny under CASS and accordingly the statutory notices were issued to the assessee. The AO found that during the financial year 2019-20, the assessee

Acc Mineral Resources Limited, Mumbai vs. Principle Commissioner of Income Tax, Mumbai-1, Mumbai

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

ITA 2687/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Jul 2025AY 2018-19

Bench: Ms. Kavitha Rajagopal, Jm & Smt. Renu Jauhri, Am Acc Minerals Resources Limited Principal Commissioner Of Income 121, Cement House, Maharshi Karve Tax, Mumbai – 400 001. Vs. Road, Church Gate, Mumbai – 400020. Pan/Gir No. Aaact2214N (Appellant) : (Respondent) Assessee By : Shri Saurabh Soparkar (Virtually Appear) Respondent By : Shri Shekhar L. Gajbhiye, Cit Dr Date Of Hearing : 29.04.2025 Date Of Pronouncement : 24.07.2025 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Assessee, Challenging The Order Of The Learned Principal Commissioner Of Income Tax, Mumbai -1 (‘Ld. Pcit’ For Short), Passed U/S.263 Of The Income Tax Act, 1961 (‘The Act'), Pertaining To The Assessment Year (‘A.Y.’ For Short) 2018-19. 2. The Assessee Has Raised The Following Grounds Of Appeal: 1. In Law & In The Facts & Circumstances Of The Appellant'S Case, Impugned Order U/S. 263 Of The Act Passed By Pcit-1, Mumbai Is Bad In Law & Deserves To Be Quashed. 2. In Law & In The Facts & Circumstances Of The Appellant'S Case, The Pcit-1, Mumbai Has Erred In Setting Aside The Assessment Order Dated 20.04.2021 Passed By The Assessing Officer Without Considering The Fact That The Assessing Officer During The Course Of Assessment Proceedings Has Already Gone Through Issue

For Appellant: Shri Saurabh Soparkar (Virtually appear)For Respondent: Shri Shekhar L. Gajbhiye, CIT DR

Section 142(1)Section 143(2)Section 143(3)Section 263Section 35D

total loss of Rs. 53,36,909/- and had claimed refund amounting to Rs. 39,41,720/-. The assessee's case was selected for complete scrutiny under e-assessment scheme, 2019 on the following issues: i. Claim of any other amount allowable as deduction in Schedule BP. ii. Refund Claim

Sadulla Syed Noorsha Syed, Nanded vs. Income Tax Officer, Nanded

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

ITA 167/PUN/2025[2018-19]Status: DisposedITAT Pune23 Jul 2025AY 2018-19

Bench: Dr.Manish Borad

For Appellant: Shri Prayag JhaFor Respondent: Shri Deepak Kumar Kedia

Section 10Section 143(2)Section 143(3)Section 250

that the assessee is an individual and filed return for A.Y. 2018-19 on 07.07.2018 declaring income of Rs.7,88,180/-. Case selected for Complete Scrutiny after valid serving of notices u/s.143(2) and 142(1) of the Act. During the year, assessee retired from Maharashtra State Electricity Distribution Company

Subhendu Nandy, Burdwan vs. I.T.O., Ward - 2(2), Burdwan

In the result, appeal of the assessee is allowed

ITA 2022/KOL/2024[2017-2018]Status: DisposedITAT Kolkata23 Jul 2025AY 2017-2018

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Subhendu Nandy Ito, Wd 2(2), Burdwan C/O S.N. Ghosh & Associates, Aaykar Bhavan, Burdwan, Advocates Sagar Mansion, 2. Kachari Road, Court Compound, Garstin Place, 2 Nd Floor, Suite P.O. & P.S. Burdwan, Dist. Vs. Nos, 202 & 203, Hare Street, Purba, Bardhaman-713101, Kolkata-700001, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aegpn0674P Assessee By : Shri Somnath Ghosh, Ar Revenue By : Shri Ruchika Sharma, Dr Date Of Hearing: 21.05.2025 Date Of Pronouncement: 23.07.2025

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri Ruchika Sharma, DR

Section 143Section 143(2)Section 143(3)Section 40Section 69A

instruction, the notice issued u/s 143(2) of the Act is neither of three formats namely; (i) Limited Scrutiny (Computer Aided Scrutiny Selection) (ii) Complete Scrutiny (computer Aided Scrutiny Selection) (iii) Compulsory Manual Scrutiny. The ld. AR submitted that in Para No.3 of the said instruction, it was stated that ... dated 09.08.2018, specifies only computer aided scrutiny selection which neither mentioned it either to be a limited or a complete scrutiny nor compulsory manual scrutiny. Thus, the said notice has been issued in violation of the instruction issued by CBDT as noted above. In our opinion, the revenue authorities have

Ningaiah Siddu, Mysore vs. DCIT, Circle-1(1)& Tps, Mysore

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

ITA 921/BANG/2025[2020-21]Status: DisposedITAT Bangalore23 Jul 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2020-21

For Appellant: Shri Ravishankar, AdvocateFor Respondent: Shri Subramanian, Jt.CIT (DR)(ITAT), Bengaluru

Section 144Section 57Section 69C

that assessee is an individual, filed his return of income on 31.3.2021 declaring total income of Rs.43,01,340. The case was selected for complete scrutiny. Necessary notices were issued. The ld. AO issued 3 notices, but none of them were complied with and therefore show cause notice was also

Radhey Shyam Saini, Hisar vs. Principal Commissioner of Income Tax, Rohtak

In the result, appeal of the assessee is allowed

ITA 2359/DEL/2024[2014-15]Status: DisposedITAT Delhi23 Jul 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2014-15 Vs. Pcit, Sh. Radhey Shyam Saini, H. No. 1174/334, Rohtak Ramlila Chowk, Hisar, Haryana Pan: Bxhps4356Q (Appellant) (Respondent) Assessee By Sh. Kuldeep Khera, Ca Sh. Mohit Girdhar, Ca Department By Sh. Mahesh Kumar, Cit(Dr) Date Of Hearing 15.07.2025 Date Of Pronouncement 23.07.2025 Order Per Satbeer Singh Godara, Jm This Assessee’S Appeal For Assessment Year 2014-15, Arises Against The Principal Commissioner Of Income Tax [In Short, The “Pcit”], Rohtak’S Order No. Itba/Rev/F/Rev5/2023- 24/1062878555(1), Dated 18.03.2024 Involving Proceedings Under Section 147 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Heard Both The Parties. Case File Perused. 2. It Emerges During The Course Of Hearing That The Sole Substantive Issue Between The Parties Is That Of Correctness Of The Learned Lower Authorities Action Assessing The Assessee’S Interest Component Of Land Acquisition Compensation U/S 28 Of The Land Acquisition Act, 1894, While Invoking Section 57(Iv) R.W.S. 56(1)(A) R.W.S. 145A(B) Of The Act. 3. Learned Sr. Dr Representing The Department Vehemently Argued That The Instant Issue Is No More Res Integra In Light Of Mahender Pal Narang Vs. Cbdt (2020) 423 Itr 13 (P&H) As Well As Pcit Vs. Inderjit Singh Sodhi Huf (2024) 161 Taxmann.Com 301 (Del.) Wherein The Department Has Succeeded Before Their Lordships That The Impugned Interest Component Ought To Be Assessed As Income From “Other” Sources Only. 4. We Have Given Our Thoughtful Consideration To The Assessee’S Pleadings & Revenue’S Foregoing Vehement Contention. It Emerges That This Tribunal’S Recent Decision In Pawan Kumar Vs. Pcit (2024) 159 Taxmann.Com 61 (Del.-Trib.) Has Distinguished The Said Case Law As Under:

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 claim and winning from Lottery/crossword puzzle/horse races. The Ld. Assessing Officer ("AO") served

Shammi Nagpal HUF, Hisar vs. Principal Commissioner of Income Tax, Rohtak

In the result, appeal of the assessee is allowed

ITA 2358/DEL/2024[2013-14]Status: DisposedITAT Delhi23 Jul 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2013-14 Vs. Pcit, Shammi Nagpal Huf, H. No. 7, Sector-13, Hissar, Rohtak Haryana Pan: Aazhs3505D (Appellant) (Respondent) Assessee By Sh. Kuldeep Khera, Ca Sh. Mohit Girdhar, Ca Department By Sh. Mahesh Kumar, Cit(Dr) Date Of Hearing 15.07.2025 Date Of Pronouncement 23.07.2025 Order Per Satbeer Singh Godara, Jm This Assessee’S Appeal For Assessment Year 2013-14, Arises Against The Principal Commissioner Of Income Tax (In Short “The Pcit”), Rohtak’S Din & Order No. Itba/Rev/F/Rev5/2023- 24/1062887031(1), Dated 19.03.2024 Involving Proceedings Under Section 147 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Heard Both The Parties. Case File Perused. 2. It Emerges During The Course Of Hearing That The Sole Substantive Issue Between The Parties Is That Of Correctness Of The Learned Lower Authorities Action Assessing The Assessee’S Interest Component Of Land Acquisition Compensation U/S 28 Of The Land Acquisition Act, 1894, While Invoking Section 57(Iv) R.W.S. 56(1)(A) R.W.S. 145A(B) Of The Act. 3. Learned Sr. Dr Representing The Department Vehemently Argued That The Instant Issue Is No More Res Integra In Light Of Mahender Pal Narang Vs. Cbdt (2020) 423 Itr 13 (P&H) As Well As Pcit Vs. Inderjit Singh Sodhi Huf (2024) 161 Taxmann.Com 301 (Del.) Wherein The Department Has Succeeded Before Their Lordships That The Impugned Interest Component Ought To Be Assessed As Income From “Other” Sources Only. 4. We Have Given Our Thoughtful Consideration To The Assessee’S Pleadings & Revenue’S Foregoing Vehement Contention. It Emerges That This Tribunal’S Recent Decision In Pawan Kumar Vs. Pcit (2024) 159 Taxmann.Com 61 (Del.-Trib.) Has Distinguished The Said Case Law As Under:

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

Shree Infra, Surat vs. Pr. CIT-1, Surat

In the result, the appeal of the assessee is dismissed

ITA 601/SRT/2024[2018-19]Status: DisposedITAT Surat22 Jul 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

For Appellant: Shri Suresh K Kabra, CAFor Respondent: Shri Aashish Pophare, CIT DR

Section 143(3)Section 23(1)Section 23(5)Section 263

assessee filed its return of income for the Assessment Year 2018-19 on 27.09.2018, declaring 'Nil' income. The case was subsequently selected for complete scrutiny with the specific parameter of "Income from Real Estate Business." The assessment was completed under section 143(3) of the Act by the Assessing Officer