“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

Shri Gajraj Natubha Jethva, Jamnagar vs. The ITO Ward-3 (2), Jamnagar

In the result, appeal filed by the assessee is allowed in terms indicated above

ITA 426/RJT/2023[2016-17]Status: DisposedITAT Rajkot17 Jun 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 426/Rjt/2023 ("नधा"रणवष" / Assessment Year: (2016-17) (Hybrid Hearing) Gajraj Natubha Jethva Vs. Income Tax Officer, Ito Ward – Sikka Patiya, Moti Khavadi, 3(2), Taranjali Building, Nr. Amber Jamnagar-361140 Cinema, Pt. Nehru Marg, Hospital Road Jamnagar - 361140 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Akypj9388E (Appellant) (Respondent) Appellant By : Smt. Astha Maniyar, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 24/03/2025 Date Of Pronouncement : 17/06/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm:

For Appellant: Smt. Astha Maniyar, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 133(6)Section 142(1)Section 143(1)Section 143(3)Section 250

Income on 13.10.2016 declaring total income at Rs.4.85.800/-. The same was processed u/s. 143(1) of the Act. The case was selected for complete scrutiny through CASS for the reason - Law Income compared to large commission receipts. A Notice u/s. 142(1) dated 22.05.2018 and subsequently notice u/s.142(1) r.w.s

I P Constructions P.Ltd, New Delhi vs. ACIT, Circle-12(2), New Delhi

In the result, the appeal of assessee is allowed

ITA 63/DEL/2023[2017-18]Status: DisposedITAT Delhi17 Jun 2025AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2017-18 M/S. I.P. Constructions Private Vs. Acit, Limited, 210 First Floor, Phool Circle-12(2), Singh Market Main, Delhi Vikas Marg, New Delhi Pin 1100 92 Pan No. Aabci4548K (Appellant) (Respondent)

For Appellant: Shri Vishal Chandra Gupta, CAFor Respondent: Shri Om Prakash, Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 154Section 250Section 36(1)(a)

company filed its return of income on 28.10.2017 declaring loss of Rs.58,95,680/- for assessment year 2017-18. The case was selected for complete scrutiny under CASS. Notice under Section 143(2) of the Act dated 16.08.2018 was issued. On change of office, notice under Section

M/S Tega Industries Ltd., Kolkata vs. DCIT, Circle-11(1), Kolkata

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

ITA 2597/KOL/2024[2021-22]Status: DisposedITAT Kolkata16 Jun 2025AY 2021-22

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(2)Section 143(3)Section 144BSection 144C(5)Section 244ASection 92BSection 92CSection 92C(3)

resistant lining components required for grinding, sizing and beneficiation of minerals, and downstream equipment used in the aforesaid industries. The case was selected for complete scrutiny through Computer Assisted Scrutiny Selection (in short 'CASS'). Accordingly, notice u/s 143(2) of the Act dated 28.06.2022 was issued and served upon

Aura Gold Pvt. Ltd., Delhi vs. ITO, Ward-3(4), Delhi

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

ITA 2435/DEL/2024[2012-13]Status: DisposedITAT Delhi16 Jun 2025AY 2012-13

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singh[Assessment Year: 2012-13] Aura Gold Pvt. Ltd. Income Tax Officer, Shop No.2, First Floor, Ward-3(4), 1164, Kucha Mahajani, Vs Room No.381, C.R. Building, Chandni Chowk, New Delhi-110002 Delhi-110006 Pan-Aaica9325K Assessee Revenue

Section 143(3)Section 147Section 68

Share capital during AY 2012-13 by Rs. ii) The case of M/s Aura Gold Pvt. Ltd. has been assessed u/s 143(3) under complete scrutiny. The issue of share premium has already been examined during the assessment u/s 143(3) of the Income Tax Act, 1961 and no adverse

Sourabh Kumar Vishamvar Singh, Adajan Surat vs. ITO Ward 2(5), Income Tax Office, Court Area, Near Jamui More

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

ITA 331/PAT/2023[2017-18]Status: DisposedITAT Patna12 Jun 2025AY 2017-18

Bench: Shri Duvvuru Rl Reddy(Through Virtual Hearing At Kolkata) Sourabh Kumar Vishamvar Vs Ito, Ward-2(5), Near Jamui Singh, More, Lakhisarai, A-301, Keshav Complex, Bihar Honey Park Road, Adjan, Surat Gujarat-395009 Pan No. :Cgspk 5166 K (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्धाररती की ओर से /Assessee By : Shri Mehul Shah, Ca रधजस्व की ओर से /Revenue By : Shri Ashwani Kr. Singal, Jcit सुनवाई की तारीख / Date Of Hearing : 23/04/2025 घोषणा की तारीख/Date Of Pronouncement : 12/06/2025 आदेश / O R D E R The Present Appeal Is Directed At The Instance Of Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-3, Patna, Dated 18.09.2023 Passed For Assessment Year 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal :- 1. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Learned Cit(A) Has Erred In Confirming The Action Of The Assessing Officer In Making Addition Of Rs. 24,00,000/- On Account Of Unexplained Cash Credit U/S. 68 Of The I.T Act, 1961. 2. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Learned Cit(A) Has Erred In Confirming The Action Of The Assessing Officer In Taxing The Addition By Taking The Rate @77.25% By Attracting S. 115Bbe Instead Of Normal Tax Rate. 3. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Learned Cit(A) Has Erred In Confirming The Action Of The Assessing Officer In Taxing The Income U/S 115Bbe @ 77.25% In A Retrospective Manner By Applying The Duly Substituted S.115Bbe Inserted Retroactive Instead Of Taxing It At 35.54% As Per The Old Provisions Of S.115Bbe.

For Appellant: Shri Mehul Shah, CAFor Respondent: Shri Ashwani Kr. Singal, JCIT

Section 115BSection 68

business of transportation of goods by road and filed his return of income on 06.12.2017. The case of the assessee was selected for complete scrutiny under the issue of “cash deposit during demonetization period”. In compliance to the statutory notices issued during the course of assessment proceedings, the assessee produced

The Kalakkodu Service Co-Operative Bank Ltd No.1194, Kollam vs. ITO, Ward 2, Kollam

In the result, both the appeals filed by the assessee are allowed and both the connected stay applications are dismissed

ITA 22/COCH/2025[2018-19]Status: DisposedITAT Cochin12 Jun 2025AY 2018-19

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

For Appellant: Shri Sabu C S, CAFor Respondent: Shri Suresh Sivanandan IRS, CIT DR and Smt

Section 143(2)Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

declaring taxable income as Nil after claiming deduction u/s 80P(2)(a)(i) of the Act. The case of the assessee was selected for complete scrutiny under CASS followed by notices u/s 143(2) and 142(1) of the Act. The assessee submitted various compliance in response to the said

The Kalakkodu Service Co-Operative Bank Ltd No.1194, Kollam vs. ITO, Ward 2, Kollam

In the result, both the appeals filed by the assessee are allowed and both the connected stay applications are dismissed

ITA 21/COCH/2025[2016-17]Status: DisposedITAT Cochin12 Jun 2025AY 2016-17

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

For Appellant: Shri Sabu C S, CAFor Respondent: Shri Suresh Sivanandan IRS, CIT DR and Smt

Section 143(2)Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

Mahesh Dyeing and Printing Mills Pvt. Ltd., Surat vs. Dy. Commissioner of Income Tax, Circle -1(1)(1), Surat

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

ITA 281/SRT/2023[2014-15]Status: DisposedITAT Surat11 Jun 2025AY 2014-15

Bench: Ms Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.281/Srt/2023 Assessment Year: (2014-15) (Hybrid Hearing) Mahesh Dyeing & Printing Mills Vs. Dcit, Pvt. Ltd., Circle – 1(1)(1), 104, 105, 107 Shivanand Nagar Surat Ind. Estate, Village – Tati Thaiya, Surat – 394221, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabcm9282E (Appellant) (Respondent) Appellant By Shri Rasesh Shah, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 02/06/2025 Date Of Pronouncement 11/06/2025

Section 250Section 68

that the assessee filed his e-return of income on 27.09.2014, declaring total income of Rs.19,79,838/-. The case was selected for complete scrutiny under CASS. Various statutory notices were issued to the assessee. The assessee company is engaged in the business of processing of fabrics on job-work

Mahansaria Enterprises Pvt Ltd, Mumbai vs. Pr. CIT, Mumbai-5, Mumbai

In the result, the appeal of the assessee is allowed

ITA 2158/MUM/2025[2020-21]Status: DisposedITAT Mumbai11 Jun 2025AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2020-21 Mahansaria Enterprises Private The Principal Commissioner Of Limited, Income Tax (Pcit), 301-304, 3Rd Floor, Vs. Room No. 515, 5Th Floor, Peninsula Chambers, Aayakar Bhavan, Peninsula Corporate Park, Maharshi Karve Road, G.K. Marg, Lower Parel West, Mumbai-400020 Mumbai-400026 Pan : Aaacy1568L (Appellant) (Respondent) For Assessee : Shri Vipul Joshi, Adv. & Prashant Bhumare For Revenue : Shri Satyaprakash R. Singh, Cit-Dr Date Of Hearing : 14-05-2025 Date Of Pronouncement : 11-06-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Principal Commissioner Of Income Tax, Mumbai-5 [„Ld.Pcit‟] U/S. 263 Of The Income Tax Act, 1961 („The Act‟), Dated 17-03-2025, Pertaining To Assessment Year (Ay) 2020-21, Wherein The Assessee Has Taken The Following Grounds Of Appeal:

For Appellant: Shri Vipul Joshi, Adv. &For Respondent: Shri Satyaprakash R. Singh, CIT-DR

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

case are that the assessee filed its original return of income on 15-02-2021. The case was selected for scrutiny through CASS under complete scrutiny category and the assessment was completed u/s. 143(3) r.w.s. 144B of the Act vide order dt. 22-09-2022, determining the total income ... further submitted that the case of the assessee was selected for complete scrutiny and one of the reasons for selection of the case relates to examination of deduction from total income under Chapter-VIA of the Act 8 and business expenses. It was submitted that during the course of assessment

Ashok Kumar, Gurgaon vs. ITO Ward1(5), Gurgaon

In the result, impugned order is upheld and appeal of the assessee is dismissed

ITA 1639/DEL/2019[2015-16]Status: DisposedITAT Delhi11 Jun 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri Amitabh Shuklaआअसं.1639/िद"ी/2019(िन.व. 2015-16) Ashok Kumar, H.No. M-231, South City-1, Gurgaon, Haryana 122001 ...... अपीलाथ"/Appellant Pan: Alypk-0003-G बनाम Vs. Income Tax Officer, Ward 1(5), ..... "ितवादी/Respondent Gurgaon, Haryana Assessee By : None Department By: Shri Ashish Tripathi, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 12/03/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 11/06/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-1, Gurgaon (Hereinafter Referred To As 'The Cit(A)') Dated 18.12.2018, For Assessment Year 2015-16. 2. A Perusal Of Appeal File Shows That The Appeal Was Filed In The Year 2019 & Thereafter, The Appeal Was Listed For Hearing On Fifteen Dates. On Most Of The Dates Fixed For Hearing None Appeared To Represent The Assessee & On Some Dates Wherever Representative Of The Assessee Appeared, Adjournment Was Sought. It Seems

For Appellant: NoneFor Respondent: Shri Ashish Tripathi, Sr. DR

Section 143(3)Section 54FSection 69

consideration of property in ITR is less than sale consideration reported in Form No. 26 QB. Subsequently, the case of assessee was converted to complete scrutiny with the approval of Principal Commissioner of Income Tax, Gurgaon vide letter dated 16.11.2017. The assessee filed his return of income for impugned assessment

Zuari Industries Limited (Formerly Known As Zuari Global Ltd), Zuarinagar vs. Deputy Commissioner of Income Tax, Circle - 1(1), Panaji

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

ITA 71/PAN/2025[2018-19]Status: DisposedITAT Panaji10 Jun 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.71/Pan/2025 (A.Y. 2018-19 ) Zuari Industries Limited, Vs National Faceless Jai Kisaan Bhawan, Assessment Centre, Zuarinagar, Delhi. Mormugo, Goa-403728. Pan/Gir No. Aaacz0306P (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By Shri.Ankit Goyal.Ar Revenue By Shri.Captain Pradeep Arya.Dr सुनवाई क" तार"ख/Date Of Hearing 10.06.2025 घोषणा क" तार"ख/Date Of Pronouncement 11.06.2025 Order Per Pavan Kumar Gadale Jm: The Appeal Is Filed By The Assesse Against The Order Of National Faceless Appeal Centre (Nfac) Delhi /Cit(A) Passed U/Sec 143(3) & U/Sec 250 Of The Act. The Assesse Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Disallowance U/Sec14Aof The Act & Not Condoning The Delay In Filling The Appeal. 2. The Brief Facts Of The Case Are That, The Assesse Company Is Engaged In The Business. The Assesse Has Filed The Return Of Income For A.Y.2018-19 On 29.11.2018 Disclosing

Section 14A

income was processed u/sec143(1) of the Act determining the total income of Rs.6,14,20,880/-.Subsequently the case was selected for complete scrutiny under CASS and the notice u/sec143(2) and u/sec142(1) of the Act along with questionnaire are issued. In compliance, the assesse has submitted

Satishbhai Mohanbhai Zalavadia, Na vs. Ari, Vs.the Principal Commissioner of Income Tax, Rajkot-1, Rajkot

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

ITA 122/RJT/2022[2017-18]Status: DisposedITAT Rajkot10 Jun 2025AY 2017-18

Bench: Dr. A.L. Saini, Am & Shri Dinesh Mohan Sinha, Jm आयकर अपील सं./Ita No.122/Rjt/2022 ("नधा"रण वष" / Assessment Year: (2017-18) (Physical He Aring) Satishbhai Mohanbhai Zalavadia, The Pr. Cit – 1, Vs. 2622, Sarvoday Park, Khundh Rajkot Khundh, Chikhli, Navsari - 396521 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acnpp0527F (Appellant) (Respondent) Appellant By : Shri Rajendra Singhal, Ar Respondent By : Shri Shramdeep Sinha, Cit-Dr Date Of Hearing : Heard On 23/07/2024 & Refix For Clarification On 24.04.2025

For Appellant: Shri Rajendra Singhal, ARFor Respondent: Shri Shramdeep Sinha, CIT-DR

Section 143(2)Section 143(3)Section 263

income for assessment year (AY) 2017-18, on 17/10/2017, declaring total income of Rs.28,30,501/-. The assessee`s case was selected for complete scrutiny to verify cash deposit in the bank account during the year under consideration. Thereafter, the assessment was completed u/s 143(3) of the Income

Abdulrasheed Arachamveettil, Thrissur vs. DCIT Circle 1(1)& Tps Thrissur, Thrissur

The appeal of the assessee is allowed for statistical purposes

ITA 374/COCH/2025[2018-19]Status: DisposedITAT Cochin10 Jun 2025AY 2018-19

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarmaassessment Years: 2018-19 Abdul Rasheed Arachamveettil Dcit, Circle-1(1) & Tps V. Thrissur No.2, Rajash Manzil, Chavakkad, Thrissur, Kerala – 680506. Pan : Abnpa4382K. (Appellant) (Respondent) Appellant By : None Respondent By : Smt. Leena Lal, Snr Ar Date Of Hearing : 04.06.2025 Date Of Pronouncement : 10.06.2025 O R D E R Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 05.05.2025 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’).

For Appellant: NoneFor Respondent: Smt. Leena Lal, Snr AR

Section 143(1)Section 143(3)Section 250

without considering the business loss of Rs.7,01,514 claimed by the assessee. Later on, the case of the assessee was selected for complete scrutiny for the reason of source of Loan Advanced and the assessment was completed under section 143(3) of the Act on 03.04.2021 determining the total

Cambridge Technology Enterprises Limited, Hyderabad vs. DCIT, Circle -1, Hyderabad

ITA 388/HYD/2022[2012-13]Status: DisposedITAT Hyderabad10 Jun 2025AY 2012-13

Bench: the Dispute Resolution Panel - 1, Bangalore (for short “DRP”). The DRP, vide its order u/s 144C(5) of the Act, dt.25.10.2016 after considering the objections rejected the adjustment of Rs.7.25 crores (supra) suggested by the TPO and directed the A.O. to make an addition of Rs.10,21,789/- towards shortfall of ALP adjustment by charging 5% mark up on the reimbursement of expenses transactions. Accordingly, the A.O. vide his assessment order passed u/s 143(3) r.w.s.144C(13), dated 29.11.2016 f

For Appellant: Shri P. Murali MohanFor Respondent: Shri Narender Kumar

Section 115JSection 143(3)Section 144CSection 144C(5)Section 263Section 37(1)Section 92C

Rs.1,47,09,173/- under the provisions of Section 115JB of the Act. Subsequently, the case of the assessee was selected for complete scrutiny under CASS. 3. During the course of assessment proceedings, the A.O. made a reference to the Deputy Commissioner of Income Tax (TPO-1), Hyderabad, (for short

Pramod Lakra, Deputy Commissioner of Income Tax, Circle -11(1), Kolkata vs. Philips Carbon Black Ltd, Kolkata

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 2459/KOL/2024[2021-22]Status: DisposedITAT Kolkata10 Jun 2025AY 2021-22