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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

Prafulla Shantilal Kothari, Pune vs. ACIT, Circle 7, Pune

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

ITA 922/PUN/2025[2017-18]Status: DisposedITAT Pune30 Jun 2025AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.922/Pun/2025 िनधा"रण वष" / Assessment Year: 2017-18 Prafulla Shantilal Kothari, Vs. Acit, Circle-7, Pune. Flat No.1, Akshay Plaza, Ramnagar, Wadgaonsheri, Pune- 411014. Pan : Aahhp4593E Appellant Respondent Assessee By : Shri Suhas Bora, Shri Saukhya Lakade & Miss Riya Oswal Revenue By : Shri Akhilesh Srivastva Date Of Hearing : 30.06.2025 Date Of Pronouncement : 30.06.2025 आदेश / Order Per R. K. Panda, Vp : This Appeal Filed By The Assessee Is Directed Against The Order Dated 24.02.2025 Passed By Ld. Addl./Jcit(A)-1, Visakhapatnam [‘Ld. Cit(A)’] For The Assessment Year 2017-18. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Huf & Is Carrying On Business Of Online Trading In Lottery Tickets Under The Name & Style ‘J.K. Lottery’. It Filed Its Return Of Income On 24.10.2017 Declaring Total Income Of Rs.51,25,350/-. The Case

For Appellant: Shri Suhas BoraFor Respondent: Shri Akhilesh Srivastva
Section 143(2)Section 37(1)

style ‘J.K. Lottery’. It filed its return of income on 24.10.2017 declaring total income of Rs.51,25,350/-. The case 2 was selected for complete scrutiny under CASS. Accordingly, statutory notices u/s 143(2) and 142(1) of the Act were issued and served upon the assessee, in response ... 24/10/2017, declaring the total income as Rs 51,25,350/-. The case was selected for scrutiny under CASS under the 'Complete scrutiny criteria. During the year under consideration, the assessee has shown profits and gains from business and profession and income from other sources. Statutory notices were issued

Antony Sunil, Chennai vs. ITO, Ncw-1(7), Chennai

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

ITA 815/CHNY/2025[2017-18]Status: DisposedITAT Chennai30 Jun 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.815/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Antony Sunil, Vs. The Income Tax Officer, No. 59, 11Th Trust Cross Street, Non Corporate Ward 1(7), Mandavelipakkam, Chennai 600 028. Chennai 600 034. [Pan:Bxbps7987P] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Anandd Babunath, F.C.A. ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 04.06.2025 घोषणा की तारीख /Date Of Pronouncement : 30.06.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 23.11.2023 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. We Find That This Appeal Is Filed With A Delay Of 415 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, We Find The Reasons Stated By The Assessee Are Bonafide, Which Really

For Appellant: Shri Anandd Babunath, F.C.AFor Respondent: Ms. R. Anita, Addl. CIT
Section 142(1)Section 143(2)Section 143(3)Section 44ASection 50CSection 55ASection 56(2)Section 69

that the assessee file return of income for AY 2017-18 admitting total income of ₹.5,50,830/- and the case was selected for complete scrutiny under CASS. Note under section 143(2) of the Income Tax Act, 1961 [“Act” in short] dated 27.09.2018 and notices under section

Perumal Pillai Muthiah Pillai Sankaranarayanan, Srivilliputtur vs. Assistant Commissioner of Income Tax, Circle-1, Virudhunagar, Income Tax Office

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

ITA 478/CHNY/2025[2017-2018]Status: DisposedITAT Chennai30 Jun 2025AY 2017-2018

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.478/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Perumal Pillai Muthiah Pillai Vs. The Assistant Commissioner Of Sankaranarayanan, No. 1A, Income Tax, Krishnankoil, Vpm Nagar, Circle – 1, Srivilliputtur, Virudhunagar District, Virudhunagar. Tamil Nadu 626 190. [Pan:Avkps6163K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T. Vasudevan, Advocate ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 05.06.2025 घोषणा की तारीख /Date Of Pronouncement : 30.06.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 14.03.2023 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. We Find That This Appeal Is Filed With A Delay Of 628 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, We

For Appellant: Shri T. Vasudevan, AdvocateFor Respondent: Ms. R. Anita, Addl. CIT
Section 142(1)Section 143(2)Section 143(3)Section 68

that the assessee file return of income for AY 2017-18 admitting total income of ₹.17,51,030/- and the case was selected for complete scrutiny under CASS. Note under section 143(2) of the Income Tax Act, 1961 [“Act” in short] dated 30.08.2018 and notices under section

Mr. Anil Jagannath Kedar, Solapur vs. Ward 1(2), Solapur

In the result, appeal of the assessee is partly allowed

ITA 567/PUN/2024[2017-18]Status: DisposedITAT Pune26 Jun 2025AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.567/Pun/2024 िनधा"रण वष" / Assessment Year: 2017-18 Mr. Anil Jagannath Kedar, V The Income Tax Officer, At Post-Wasud, Sangola, S Ward-1(2), Solapur. Dist – Solapur – 413307. Maharashtra. Pan : Asvpk0584A Appellant/ Assessee Respondent / Revenue Assessee By Shri Piyush Bafna & Shri Aakash Parakh – Ar’S Revenue By Shri Rajesh Haladkar – Addl.Cit(Dr) Date Of Hearing 25/06/2025 Date Of Pronouncement 26/06/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(Appeal)-7, Kolkata Passed Under Section 250 Of The Income Tax Act, 1961, For The A.Y.2017-18, Dated 24.01.2024 Emanating From The Assessment Order U/S.144 Of The Income Tax Act, 1961, Dated 19.12.2019. The Assessee Has Raised The Following Grounds Of Appeal : “Appeal

Section 144Section 250

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? 5. We have heard Mr. Amit Sharma, learned standing Counsel appearing for the appellant and Mr. Abhratosh Majumder, learned senior Advocate for the respondent ... limited scrutiny were beyond jurisdiction of the Assessing Officer as the scrutiny assessment was selected for limited scrutiny under Section 143(2) and not complete scrutiny. The Department objected to the additional ground which were raised by the appellant before the Tribunal. However, the learned Tribunal overruled the said objection