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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

Madhav Copper Ltd., Bhavnagar vs. The Income Tax Officer, Ward-1(8), Bhavnagar

In the result, all six appeals, three by the Revenue and three by the assessee, stand dismissed

ITA 276/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad25 Jun 2025AY 2021-22

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokar

For Appellant: Shri Tushar Hemani, Sr.Adv., and Shri Parimalsinh B. Parmar, ARFor Respondent: Shri R.P. Rastogi, CIT-DR, and Shri Abhijit, Sr.DR
Section 143(3)Section 145(3)Section 147Section 148Section 250

rate to 5% of the impugned purchases. The balance disallowance was deleted. 4. In assessment year 2020–21, the case was selected for complete scrutiny under CASS. The AO noted that the assessee had made purchases from parties whose details were flagged by the Insight portal

Madhav Copper Ltd., Bhavnagar vs. The Income Tax Officer, Ward-1(8), Bhavnagar

ITA 275/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad25 Jun 2025AY 2020-21

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokar

For Appellant: Revenue byFor Respondent: (Responent)
Section 143(1)Section 143(1)(a)Section 143(3)Section 145(3)Section 147Section 148Section 250

rate to 5% of the impugned purchases. The balance disallowance was deleted. 4. In assessment year 2020–21, the case was selected for complete scrutiny under CASS. The AO noted that the assessee had made purchases from parties whose details were flagged by the Insight portal

Madhav Copper Ltd., Bhavnagar vs. The Income Tax Officer, Ward-1(8), Bhavnagar

ITA 274/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad25 Jun 2025AY 2018-19

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokar

For Appellant: Shri Tushar Hemani, Sr.Adv., andFor Respondent: Shri R.P. Rastogi, CIT-DR, and
Section 143(1)(a)Section 143(3)Section 145(3)Section 147Section 148Section 250

rate to 5% of the impugned purchases. The balance disallowance was deleted. 4. In assessment year 2020-21, the case was selected for complete scrutiny under CASS. The AO noted that the assessee had made purchases from parties whose details were flagged by the Insight portal

Income Tax Officer, Ward-1(8), Bhavnagar vs. Madhav Copper Limited, Bhavnagar

In the result, all six appeals, three by the Revenue and three by the assessee, stand dismissed

ITA 256/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad25 Jun 2025AY 2021-22

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokar

For Appellant: Shri Tushar Hemani, Sr.Adv., and Shri Parimalsinh B. Parmar, ARFor Respondent: Shri R.P. Rastogi, CIT-DR, and Shri Abhijit, Sr.DR
Section 143(3)Section 145(3)Section 147Section 148Section 250

rate to 5% of the impugned purchases. The balance disallowance was deleted. 4. In assessment year 2020–21, the case was selected for complete scrutiny under CASS. The AO noted that the assessee had made purchases from parties whose details were flagged by the Insight portal

Income Tax Officer, Ward-1(8), Bhavnagar vs. Madhav Copper Limited, Bhavnagar

ITA 255/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad25 Jun 2025AY 2020-21

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokar

For Appellant: Shri Tushar Hemani, Sr.Adv., andFor Respondent: Shri R.P. Rastogi, CIT-DR, and
Section 143(1)(a)Section 143(3)Section 145(3)Section 147Section 148Section 250

rate to 5% of the impugned purchases. The balance disallowance was deleted. 4. In assessment year 2020-21, the case was selected for complete scrutiny under CASS. The AO noted that the assessee had made purchases from parties whose details were flagged by the Insight portal

Income Tax Officer, Ward-1(8), Bhavnagar vs. Madhav Copper Limited, Bhavnagar

In the result, all six appeals, three by the Revenue and three by the assessee, stand dismissed

ITA 254/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad25 Jun 2025AY 2018-19

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokar

For Appellant: Shri Tushar Hemani, Sr.Adv., and Shri Parimalsinh B. Parmar, ARFor Respondent: Shri R.P. Rastogi, CIT-DR, and Shri Abhijit, Sr.DR
Section 143(3)Section 145(3)Section 147Section 148Section 250

rate to 5% of the impugned purchases. The balance disallowance was deleted. 4. In assessment year 2020–21, the case was selected for complete scrutiny under CASS. The AO noted that the assessee had made purchases from parties whose details were flagged by the Insight portal

Krishnasamy Bhuvaneswari, Coimbatore vs. ITO, Non Corprate Ward 4(2), Coimbatore

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

ITA 1528/CHNY/2023[2013-14]Status: DisposedITAT Chennai25 Jun 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1528/Chny/2023 िनधा"रण वष" / Assessment Year:2013-14 Krishnasamy Bhuvaneswari, Ito, 43/63, Rajamanai Thottam, Vs. Non Corporate Ward 4(2), Kupanur, Mathampatty, Coimbatore. Coimbatore – 641 010. [Pan:Ahypb-5938-M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri. N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri. M. K. Biju, C.I.T. - D.R. सुनवाई की तारीख/Date Of Hearing : 05.06.2025 घोषणा की तारीख/Date Of Pronouncement : 25.06.2025

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. M. K. Biju, C.I.T. - D.R
Section 263Section 263(2)

overlooked and brushed aside in as much as in this regard, ought to have appreciated that the review of the assessment order completed on complete scrutiny would be prohibited within the scope of the powers of revision under Section 263 of the Act. 6. The PCIT failed to appreciate that ... there was complete scrutiny of facts referred to in the revision order, considering the fact of selection of return of income filed for limited scrutiny proceedings, while passing the assessment order passed by the JAO and hence ought to have appreciated that the decision to direct the JAO to revisit

Raj Shipping Agencies Limited, Mumbai vs. Principal Commissioner of Income Tax -5, Mumbai

In the result, appeals of the revenue are dismissed

ITA 2853/MUM/2025[2020-21]Status: DisposedITAT Mumbai25 Jun 2025AY 2020-21

Bench: Shri Pawan Singh & Shri Prabhash Shankar(Physical Hearing) Raj Shipping Agencies Limited Pr. Commissioner Of Income Tax- Banaji Mansion, 17 Banaji Street Fort, Vs 5, Aayakarbhawan, Mumbai – 400023. Mumbai-400020. [Pan No. Aaacr3051R] Appellant / Assessee Respondent / Revenue

Section 143(3)Section 254(1)Section 263Section 80G

erred in passing an order under section 263 of the Act without appreciating that the assessment was selected for scrutiny through CASS under the complete scrutiny category and the fact that the submissions were already made before the Assessing Officer (AO) during the assessment proceedings under section

Rama University Uttar Pradesh, Kanpur vs. The Assessment Unit, Delhi

Appeal is allowed

ITA 86/DEL/2025[2020-21]Status: DisposedITAT Delhi25 Jun 2025AY 2020-21

Bench: Sh. Satbeer Singh Godaraita No. 86/Del/2025 : Asstt. Year : 2020-21 Ram University Uttar Pradesh, Vs The Assessment Unit, 2Nd Floor, E-Ramp, 100, Rama City, G. T. Road, Mandhana, U.P.-209217 Jawaharlal Nehru Stadium, New Delhi-110003 (Appellant) (Respondent) Pan No. Aadtr0638L Assessee By: Sh. Ashutosh Thakur, Adv. & Sh. Ritesh Kumar Singh, Adv. Revenue By : Ms. Indu Bala Saini, Sr. Dr Date Of Hearing: 25.06.2025 Date Of Pronouncement: 25.06.2025 Order This Assessee’S Appeal For Assessment Year 2020-21, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1067473637(1) Dated 09.08.2024, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Ashutosh Thakur, Adv. &For Respondent: Ms. Indu Bala Saini, Sr. DR
Section 143(2)Section 143(3)Section 57

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

Saumya Mittal, New Delhi vs. ACIT-1, Moradabad, Delhi

The appeal is allowed

ITA 3764/DEL/2024[2018-19]Status: DisposedITAT Delhi25 Jun 2025AY 2018-19

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2018-19 Saumya Mittal, Vs Acit-1, C10, Kalindi Colony, Moradabad. New Delhi – 110 065. Pan: Achpm0134E (Appellant) (Respondent) Assessee By : Shri Ajay Wadhwa, Advocate; Ms Ragini Handa, Advocate; & Shri Saksham Garg, Ca Revenue By : Shri Manish Gupta, Sr. Dr Date Of Hearing : 02.06.2025 Date Of Pronouncement : 25.06.2025 Order Per Anubhav Sharma, Jm:

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Shri Manish Gupta, Sr. DR
Section 143(2)Section 143(3)

submissions are that assessee filed return filed on 25.03.2019, declaring income of ₹87,30,790/ and the case of the Assessee was selected for complete scrutiny to examine foreign financial interest and notice under section 143(2) of the Act issued on 22.09.2019. During the impugned AY, the Assessee

DCIT, Circle - 19(1), New Delhi vs. Rapid Engineering Company Pvt. Ltd., New Delhi

In the result, the appeal of the assessee is allowed

ITA 3522/DEL/2024[2020-21]Status: DisposedITAT Delhi25 Jun 2025AY 2020-21

Bench: Ms. Madhumita Roy & Shri Naveen Chandrathe Dy. C.I.T Vs. Rapid Engineering Co. Pvt Ltd Circle – 19(1) 111-112, Dsidc Sheds Delhi Okhla Phase – 1, New Delhi

For Appellant: Shri Sumit Bansal, CAFor Respondent: Ms. Harpreet Kaur Hansra Sr. DR
Section 143(3)Section 50(1)Section 50C(1)Section 56(2)(x)

that the assessee filed its return of income on 31.12.2020 declaring total income of Rs. 26,99,24,830/-. The case was selected for Complete Scrutiny assessment under the Faceless Assessment Scheme, 2019. The assessee, during the year under consideration, had purchased industrial unit No. 054, Block-C. Phase

ITO, Ward-1(1), Faridabad vs. Chaman, Faridabad

In the result, appeal of the assessee is allowed

ITA 2774/DEL/2024[2017-18]Status: DisposedITAT Delhi25 Jun 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2017-18 Vs. Chaman, Income Tax Officer, Ward-1(1), H. No. 437, Sector-9, Faridabad Faridabad Pan: Bfapd6698P (Appellant) (Respondent) With C.O. No.103/Del/2024 [Arising Out Of Ita No.2774/Del/2024] Assessment Year: 2017-18 Vs. Income Tax Officer, Chaman, H. No. 437, Sector-9, Ward-1(1), Faridabad, Haryana Faridabad Pan: Bfapd6698P (Appellant) (Respondent) Assessee By Sh. Gaurav, Adv. Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 25.06.2025 Date Of Pronouncement 25.06.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No. 2774/Del/2024 & Assessee’S Cross Objection C.O. No. 103/Del/2024 For Assessment Year 2017- 18, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The

Section 147Section 250(4)

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

Fil India Business & Research Pvt. Ltd., Delhi vs. DCIT, Circle 2(1), C.R Building, Delhi

The appeal of the assesse is partly allowed

ITA 1948/DEL/2021[2017-18]Status: DisposedITAT Delhi25 Jun 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 143(3)Section 144CSection 920Section 92CSection 92C(3)

filed modified return of income on 29- 05.2019 declaring total income at Rs.124,34,58,390/-. The case of the assessee was selected for complete scrutiny. Since, the assessee has entered into international 2 IT No.1948/Del/2021 Fil India Business & Research Pvt.Ltd. vs. DCIT transactions, therefore, the reference was made

Asstt. Commissioner of Income-Tax, Circle-1, Jodhpur, Paota C Road vs. J.M. Metals, Basni

ITA 257/JODH/2024[2017-18]Status: DisposedITAT Jodhpur24 Jun 2025AY 2017-18

Bench: Dr. Mitha Lal Meena, HonʼBle & Dr. S. Seethalakshmi, Hon'Ble

IN THE INCOME TAX APPELLATE TRIBUNAL JODHPUR BENCH (Virtual) JODHPUR BEFORE DR. MITHA LAL MEENA, HONʼBLE ACCOUNTANT MEMBER AND DR

Income Tax Officer, Ward-2(1), Udaipur vs. Deepak Wahi, Udaipur

In the result, the appeal of the revenue is dismissed

ITA 410/JODH/2023[2016-17]Status: DisposedITAT Jodhpur24 Jun 2025AY 2016-17

Bench: Dr. Mitha Lal Meena, Hon'Ble & Dr. S. Seethalakshmi, Hon'Ble

Section 143(3)

Income Tax, Udaipur, vide his office letter No. 953 dated 19/07/2018, accorded the approval for conversion of the case from limited scrutiny to complete scrutiny. After hearing the assessee, the AO completed the assessment u/s. 143(3) of the Act on 19/12/2018, determining the assessee's total income

Universal Biomass Energy Private Limited, Guruharsahai vs. Income Tax Officer Ward-3(1), Ferozepur

In the result, the appeal of the assessee is allowed

ITA 267/ASR/2024[2018-19]Status: DisposedITAT Amritsar24 Jun 2025AY 2018-19

Bench: Sh. Udayan Dasgupta & Sh. Brajesh Kumar Singh

Section 139(1)Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 246ASection 250Section 80I

Rs.5,61,39,920/-, (in absence of any audit report in form 10CCB on record). 3.1 In between, the case was selected for complete scrutiny under the e- assessment scheme vide notice u/s 143(2) dated 28th September, 2019, on two particular issues: i) Investments/Advances/Loans, ii) Deduction Claimed for Industrial ... after the date of selection of the case for scrutiny vide issue of statutory notice u/s 143(2) dated 28th September 2019 , for complete scrutiny specifying the issue of deduction claimed for industrial undertaking u/s 80IA , which means the very same issue was already open before the assessing authority

Rishi Agarwal, Guwahati vs. ITO, Ward-2(2), Guwahati

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

ITA 266/GTY/2024[2021-22]Status: DisposedITAT Guwahati24 Jun 2025AY 2021-22

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 143(3)Section 250Section 69C

income for the A.Y. 2021-22 electronically furnished on 25/12/2021 vide acknowledgement No.420225080251221 declaring income of Rs.13,02,740/-. The case was selected for complete scrutiny under CASS. A Notice u/s 143(2) was issued on 28/06/2022 and duly served upon the assessee. Thereafter, to examine the CASS reason, notices ... appellant assessee in its submissions have stated that, “…..That the case of the appellant for the F.Y 2020-21 was selected for complete scrutiny and according notices were received by the appellant from time to time. In response of the notice issued u/s 142(1) dated 13.10.2022, the appellant duly

Mohmmedayaz Janmohmmed Shaikh, Ahmedabad vs. The ITO, Ward-1(3)(1), Ahmedabad

In the result, the appeal of the assessee is partly allowed

ITA 198/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad24 Jun 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Deepak R Shah, A.RFor Respondent: Shri B. P. Srivastava, Sr. DR
Section 143(2)Section 68

income for the Assessment Year 2017–18 on 08.03.2018, declaring a total income of Rs. 4,01,340/-. The case was subsequently selected for complete scrutiny, and a notice under Section 143(2) of the Act was issued on Mohmmedayaz Janmohmmed Shaikh vs. ITO Asst.Year –2017-18 - 2– 14.08.2018. During

Bpo Solutions Private Limited (Successor to M/S. Arcee Finvest Limited), Kolkata vs. DCIT, Circle 1(1), Kolkata

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

ITA 438/KOL/2025[2017-18]Status: DisposedITAT Kolkata24 Jun 2025AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 438/Kol/2025 Assessment Year: 2017-2018 Bpo Solutions Private Limited,……….………Appellant (Successor To M/S. Arcee Finvest Limited) Infinity, Plot A3, Block Gp, Salt Lake, North 24-Parganas, Kolkata-700091 [Pan:Aafca4260N] -Vs.- Deputy Commissioner Of Income Tax,…....Respondent Circle-1(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri Akkal Dudhwewala, Fca, Appeared On Behalf Of The Assessee Shri Raja Sengupta, Cit, D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: June 16, 2025 Date Of Pronouncing The Order: June 24, 2025 O R D E R

Section 143(3)Section 14ASection 68

income after adjustment of brought forward loss of Rs.59,65,801/- and current year loss of Rs.4,32,973/-. The return was selected for complete scrutiny assessment through CASS. Notices under sections 143(2) and 142(1) were issued and duly served on the assessee-Company. In response

J K Traders, Thiruchendur vs. ITO, Ward-2, Tuticorin

ITA 566/CHNY/2025[2017-18]Status: DisposedITAT Chennai24 Jun 2025AY 2017-18
For Appellant: Shri Veerabathran Prasanth, AdvocateFor Respondent: Shri C.P. Solomon, JCIT
Section 143(3)Section 2(1)(a)Section 250Section 5Section 69A

assessment year 2017-18, the return of income was filed on 01.11.2017 declaring total income of Rs.2,07,690/-. The case was selected for complete scrutiny for the reason that there was cash deposits, for a sum of Rs.26,82,000/- into the assessee's bank account in Specified Bank