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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

Virutcham Micro Finance Ltd., Madurai vs. ITO, Corp. Circle.2, Madurai

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

ITA 1313/CHNY/2025[2017-18]Status: DisposedITAT Chennai18 Jul 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1313/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Virutcham Micro Finance Limited, Vs. The Assistant Commissioner Of C-50, Gurudev Nagar, Avaniyapuram Income Tax, Bypass Road, Madurai 625 002. Corporate Circle 2, Madurai. [Pan:Aaccv9529Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Ms. V. Supraja, Addl.Cit सुनवाई की तारीख/ Date Of Hearing : 16.07.2025 घोषणा की तारीख /Date Of Pronouncement : 18.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.03.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. When The Appeal Was Taken Up For Hearing On 16.07.2025, We Find No Representation On Behalf Of The Assessee. Further, On Perusal Of The Record, We Find That The Notice Issued On 18.06.2025 Returned

For Appellant: NoneFor Respondent: Ms. V. Supraja, Addl.CIT
Section 115BSection 115JSection 4Section 68

under normal provisions and deemed income of ₹.21,17,239/- under section 115JB of the Act. The case was selected for complete scrutiny and issued statutory notices under sections 143(2) and 142(1) of the Act. On verification of the details filed by the assessee in response to various

Kongu Welfare Trust, Villupuram vs. ITO, Exemptions Ward-1, Chennai

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

ITA 1298/CHNY/2025[2018-19]Status: DisposedITAT Chennai18 Jul 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1298/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 Kongu Welfare Trust, Vs. The Income Tax Officer, No.2/1, Vijayapuram Iind Street, Exemptions Ward 1, Chinnasalem – Tk, Villipuram, Chennai. Villupuram 606 201. [Pan:Aactk2793E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Mudit Bohra, Advocate ""थ" की ओर से/Respondent By : Ms. V. Supraja, Addl.Cit सुनवाई की तारीख/ Date Of Hearing : 16.07.2025 घोषणा की तारीख /Date Of Pronouncement : 18.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 20.03.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2018-19. 2. The Assessee Raised 6 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is 2

For Appellant: Shri Mudit Bohra, AdvocateFor Respondent: Ms. V. Supraja, Addl.CIT
Section 10Section 12ASection 142(1)Section 143(3)Section 164(2)Section 2(15)

claimed exemption under section 10(23C)(iiiad) of the Income Tax Act, 1961 [“Act” in short]. The return was selected for complete scrutiny and the Assessing Officer issued notice under section 142(1) of the Act along with questionnaire. The assessee has reported voluntary contribution forming part of corpus

Income Tax Officer, New Delhi vs. Anil Kumar Bhakkar, Delhi

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

ITA 4769/DEL/2024[2017-18]Status: DisposedITAT Delhi18 Jul 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanincome Tax Officer, Vs. Anil Kumar Bhakkar, New Delhi. E – 99 – B, Mansarover Garden, Delhi – 110 015. (Pan : Aampb0474B) (Appellant) (Respondent) Assessee By : Shri Ashok Agarwal, Ca Revenue By : Shri Rajesh Tiwari, Sr. Dr Date Of Hearing : 20.05.2025 Date Of Order : 18.07.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 23.09.2024 For Assessment Year 2017-18. 2. Brief Facts Of The Case Are, Assessee Filed Its Return Of Income On 27.10.2017 Declaring An Income Of Rs.9,65,820/-. The Case Was Selected For Complete Scrutiny Through Cass. Based On The Information Available With The Revenue That Assessee Has Deposited Cash Of Substantial Amount As Compared

For Appellant: Shri Ashok Agarwal, CAFor Respondent: Shri Rajesh Tiwari, Sr. DR
Section 143(2)Section 145(3)Section 68

case are, assessee filed its return of income on 27.10.2017 declaring an income of Rs.9,65,820/-. The case was selected for complete scrutiny through CASS. Based on the information available with the Revenue that assessee has deposited cash of substantial amount as compared 2 to returned income during demonetization

C-2573 Dhamalerimuthur Paccs Ltd., Tirupattur vs. ITO, Ward-1, Vellore

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

ITA 1035/CHNY/2025[2020-21]Status: DisposedITAT Chennai17 Jul 2025AY 2020-21

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.1035/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 C-2573 Dhamalerimuthur Paccs Ltd., Vs. The Income Tax Officer, 188/2, Dhamalerimuthur, Ward 1, Tirupattur, 635 853. Vellore. [Pan:Aabad1030D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Jainendar, C.A. ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 01.07.2025 घोषणा की तारीख /Date Of Pronouncement : 17.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 18.03.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2020-21. 2. The Assessee Raised 9 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Addition Made By The Assessing Officer Under 2

For Appellant: Shri Jainendar, C.AFor Respondent: Ms. R. Anita, Addl. CIT
Section 142(1)Section 143(2)Section 68Section 80P(2)(c)

case are that the assessee filed return of income declaring total income of ₹.0. The case of the assessee was selected for complete scrutiny through CASS and notice under section 143(2) of the Act dated 29.06.2021 was issued on the assessee. Various notices under section