“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

Chinnaswamy Sunder Raju, Bangalore vs. Assistant Commissioner of Income-Tax, Central Circle-2(4), Bengaluru

In the result the appeal of the assessee is partly allowed

ITA 1071/BANG/2024[2017-18]Status: DisposedITAT Bangalore09 Jun 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year : 2017-18

For Appellant: Shri. V Chandra Sekhar, AdvocateFor Respondent: Shri. Shivanand Kalakeri, CIT(DR)(ITAT), Bangalore

Section 127Section 132Section 139(4)Section 143(2)Section 143(3)Section 153A

02/03/2018 declaring income under the head(s) Income from Salary, House Property, Capital gains and other sources. The same was taken up for complete scrutiny based upon computer aided scrutiny selection (CASS)and the assessment was duly completed u/s 143(3) by order dated 21/11/2019, by determining the taxable income ... which the AO has made these additions are all recorded in the books of accounts,and which were available before the AO during the complete scrutiny proceeding which was concluded by Page 14 of 23 an assessment order u/s 143(3) dated 21/11/2019. In fact, the AO has made several

Kavita Manoj Damani, Mumbai vs. Income Tax Officerm Int Tax Ward 2(1)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 2648/MUM/2024[2020-21]Status: DisposedITAT Mumbai09 Jun 2025AY 2020-21

Section 133(6)Section 139Section 143(2)Section 143(3)Section 250Section 54Section 64(1)(iv)

facts of the case are that the assessee filed her return of income declaring total income of Rs.29,60,520/- which was selected for complete scrutiny under CASS and one of the issues for which the case was selected for scrutiny was to examine capital gains deduction claimed ... Rs.3,96,55,000/-. This new property has been purchased by the assessee from her husband. The case of assessee was selected for complete scrutiny under CASS and the notice u/s.143(2) of the I T Act, 1961 was issued on 29.06.2021 by NaFAC. The assessee being a non resident

Ishita Mahesh Hadvani, Ahmedabad vs. Income Tax Officer, Ward 2(1)(2), Rajkot

ITA 121/RJT/2025[2016-17]Status: DisposedITAT Rajkot06 Jun 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.121/Rjt/2025 Assessment Year: (2016-17) (Hybrid Hearing) Ishita Mahesh Hadvani Vs. Income Tax Officer, Ward – 504, Hetvee Tower, Azad Society, 2(1)(2) S. O. Ahmedabadz– 380015 It – Office, New Aayakar Bhavan, Vatiaka, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ajlph0459E (Appellant) (Respondent)

For Appellant: Shri Kamal Bhambhani, Ld. A.RFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 144Section 250

16/10/2016 declaring total loss of Rs. 5.05.944/-. The Appellant is dealing in shares and securities. The case of the appellant has been selected for complete scrutiny with the reason of whether sales turnover/ receipts has been correctly offered for tax and whether the investment and income related to securities transactions

Sri Jagadguru Renukacharya Co-Operative Credit Society Limited, Shiggaon vs. Income Tax Officer, Ward-1, Haveri

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

ITA 116/BANG/2025[2020-21]Status: DisposedITAT Bangalore06 Jun 2025AY 2020-21

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri Siddesh N Gaddi, CAFor Respondent: Shri Subramanian .S, JCIT-DR

Section 144Section 270ASection 80PSection 80P(2)Section 80P(2)(a)

income declaring a Nil income and claimed a deduction u/s. 80P(2)(a)(i) of the Act. Thereafter, their case was selected for complete scrutiny and the AO made the assessment orders u/s. 144 of the Act and denied the deduction claimed

Sri Jagadguru Renukacharya Co-Operative Credit Soceity Limited, Shiggaon vs. Income Tax Officer, Ward-1, Haveri

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

ITA 115/BANG/2025[2018-19]Status: DisposedITAT Bangalore06 Jun 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri Siddesh N Gaddi, CAFor Respondent: Shri Subramanian .S, JCIT-DR

Section 144Section 270ASection 80PSection 80P(2)Section 80P(2)(a)

Sri Jagadguru Renukacharya Co-Operative Credit Soceity Limited, Shiggaon vs. Income Tax Officer, Ward-1, Haveri

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

ITA 114/BANG/2025[2018-19]Status: DisposedITAT Bangalore06 Jun 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri Siddesh N Gaddi, CAFor Respondent: Shri Subramanian .S, JCIT-DR

Section 144Section 270ASection 80PSection 80P(2)Section 80P(2)(a)

Bhupendra Sharma HUF, Noida vs. ITO Ward 5(1)(2(3), Noida

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

ITA 127/DEL/2024[2018-19]Status: DisposedITAT Delhi06 Jun 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Roybhupendra Sharma Huf Vs. Cit(A) Nfac E-9, Sector-41, Noida Delhi – 110001 Uttar Pradesh- 201301 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaghb3664P Appellant .. Respondent

For Appellant: Sh. Raghav Sharma, CA, &For Respondent: Ms. Harpreet Kaur Hansra, Sr

Section 143(3)Section 263

doing so, ITAT has observed at Para 11 of the order that the Ld. PCIT has taken a view as if it is a complete scrutiny case and the AO has failed to conduct some more enquiries in the case. (ii) The order further, inter alia, says in Para

Income Tax Officer, Surat vs. The Sutex Co.Operative Bank Limited, Surat

In the result, the appeal of the revenue is dismissed

ITA 780/SRT/2024[2016-17]Status: DisposedITAT Surat05 Jun 2025AY 2016-17

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.780/Srt/2024 Assessment Year: (2016-17) (Hybrid Hearing) The Ito, Vs. The Sutex Co-Operative Bank Ltd., Ward – 1(1)(1), 2Nd Floor, Bank Block, Surat Textile Surat Market, Ring Road, Surat - 395002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaat2953Q (अपीलाथ" / Appellant) (""थ" / Respondent) Appellant By Shri Mukesh Jain, Sr. Dr Respondent By Shri Sapnesh Sheth, Ca Date Of Hearing 09/04/2025 Date Of Pronouncement 05/06/2025

Section 250Section 36(1)(via)Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

income of Rs.27,38,18,770/-. The assessee is a co- operative Bank, engaged in the business of banking. The case was selected for complete scrutiny and after hearing the assessee, the Assessing Officer (in short, ‘AO’) added Rs.50,00,000/- u/s 36(1)(viia) and Rs.1

Suraksha Vihar Co Operative Group Housing Society Limited, Faridabad vs. ITO Ward 54(1), Delhi, Civic Centre, New Delhi

Appeal is allowed

ITA 1879/DEL/2025[2016-17]Status: DisposedITAT Delhi05 Jun 2025AY 2016-17

Bench: Shri Satbeer Singh Godaraassessment Year: 2016-17 Vs. Income Tax Officer, Suraksha Vihar Co-Operative Group Housing Society Limited, Ward-54(1), Suraksha Vihar Cghs, Plot No. Delhi Gh-14, Opp. Gayatri Apartment, Sector-45, Faridabad Pan :Aadas1622E (Appellant) (Respondent) Assessee By Sh. Dishant Sethi, Adv. Department By Sh. Akhilesh Kumar Yadav, 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

Income Tax Officer, Panipat vs. Dinesh Kaushik, Panipat

In the result, appeal of the assessee is allowed

ITA 5753/DEL/2024[2018-19]Status: DisposedITAT Delhi05 Jun 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2018-19 Vs. Sh. Dinesh Kaushik, Income Tax Officer, Panipat Vpo Baljattan, Panipat, Haryana Pan: Awjpk9483E (Appellant) (Respondent) Assessee By None Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 145BSection 263Section 28Section 45(5)

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

Prem Singh Raja, Chamba vs. Principle Commissioner of Income Tax -1, Chandigarh

In the result, both the above appeals filed by the assessee are allowed

ITA 423/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh04 Jun 2025AY 2015-16

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Ajay Jain, CA and Shri Lovesh Bansal, C.AFor Respondent: Smt. Kusum Bansal, CIT, DR (Virtual Mode)

Section 263

Return of income filed for AY 2015–16 5 20.09.2016 Case selected for limited scrutiny through CASS 6 26.10.2017 Scrutiny converted to complete scrutiny with PCIT approval 7 29.12.2017 Assessment completed u/s 143(3); addition of ₹79.17 crore LTCG 8 19.03.2020 First revision order passed u/s 263 by PCIT, Shimla

Sh. Prem Singh Raja, Chamba vs. Pr. C.I.T. -1, Chandigarh

In the result, both the above appeals filed by the assessee are allowed

ITA 359/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh04 Jun 2025AY 2017-18

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Ajay Jain, CA and Shri Lovesh Bansal, C.AFor Respondent: Smt. Kusum Bansal, CIT, DR (Virtual Mode)

Section 263

M/S. Fiorenza Granito Pvt. Ltd., at. Rata Virada, Taluka: Wakaner, Dist. Morbi vs. The Pr. CIT-1, Rajkot

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

ITA 77/RJT/2021[2016-17]Status: DisposedITAT Rajkot03 Jun 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)

Section 143(3)Section 263

filed on 15.10.2016 declaring the total income at Rs. NIL. The case of the appellant was selected for the complete scrutiny. Notice issued by AO the assessee replied to the notice and the assessment was completed with undermentioned observation. i. In response to the notice issued, the assessee has filed ... 77/Rjt/2021 (AY 2016-17) FIORENZA GRANITO P. LTD. v. PCIT ii. On perusal of record, it was seen that the case was selected for complete scrutiny under CASS and one of the reasons for selection was to verify as to whether the share capital is genuine and from disclosed sources

Hiren Rameshbhai Patel, Ahmedabad vs. The Dy.CIT, Circle-3(2), Ahmedabad

ITA 681/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad03 Jun 2025AY 2016-17

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2016-17

For Appellant: Shri Biren Shah, A.RFor Respondent: Shri B.P. Srivastava, Sr. D.R

Section 143(2)Section 250Section 56(2)(vii)Section 68

assessee for assessment year 2016-17 on 29-03-2018 declaring total income at Rs. 54,59,950/-. The case was selected for complete scrutiny under CASS and the notice u/s. 143(2) of the Income Tax Act, 1961 was issued on 28-09-2018 which was duly served upon

Proxima Creations, Pune vs. PCIT, Pune-2, Pune

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

ITA 1041/PUN/2024[2018-19]Status: DisposedITAT Pune03 Jun 2025AY 2018-19

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1041/Pun/2024 िनधा"रण वष" / Assessment Year : 2018-19 Proxima Creations, Vs. Pcit, Pune-2. Prop. -1, Business Centre, Level-1, Senapati Bapat Road, Pune- 411016. Pan : Aakfp9790Q Appellant Respondent Assessee By : None Revenue By : Shri Ajay Kumar Keshari Date Of Hearing : 08.04.2025 Date Of Pronouncement : 03.06.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 13.03.2024 Passed By Ld. Pcit, Pune-2 [Ld. Pcit’] For The Assessment Year 2018-19. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. Order Passed By The Ld. Principal Cit U/S 263 Is Not Tenable Either In Law Or In The Facts Of The Case As The Order Passed By The Ao U/S 144 Did Not Contain Any Error Which Was Prejudicial To The Interest Of Revenue. 2. Order Passed By The Additional Principal Cit U/S 263 Is Bad In Law Being Violative Of Principle Of Natural Justice. 3. The Ld. Principal Cit Has Erred In Holding That Two Different Sets Of Profit & Loss Accounts Were Prepared By The Assessee.

For Appellant: NoneFor Respondent: Shri Ajay Kumar Keshari

Section 143(2)Section 144Section 263Section 45(4)

partnership firm and furnished its return of income on 31.10.2018 disclosing loss of Rs.6,00,61,758/-. The return was selected for complete scrutiny through CASS and statutory notices u/s 143(2) and 142(1) respectively were issued to the assessee along with questionnaire. Since the assessee remained absent

Income Tax Officer, Delhi vs. Gsp Power Systems Pvt. Ltd., Delhi

Accordingly, the appeal fails and is dismissed

ITA 1273/DEL/2024[2018-19]Status: DisposedITAT Delhi03 Jun 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2018-19 Vs. Gsp Power Systems Pvt. Ltd., Income Tax Officer, New Delhi 22, 3Rd Floor, Main Market, Moti Nagar, New Delhi Pan: Aaccg0581H (Appellant) (Respondent) With C.O. No.40/Del/2024 [Arising Out Of Ita No.1273/Del/2024] Assessment Year: 2018-19 Gsp Power Systems Pvt. Vs. Income Tax Officer, Ltd., Ward-10(1), 22, 3Rd Floor, Main Market, New Delhi Moti Nagar, New Delhi Pan: Aaccg0581H (Appellant) (Respondent) Assessee By Dr. Rakesh Gupta, Adv. Sh. Somil Agarwal, Adv. Department By Ms. Suman Malik, Cit(Dr) Date Of Hearing 03.06.2025 Date Of Pronouncement 03.06.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No.1273/Del/2024 & Assessee’S Cross Objection C.O. No. 40/Del/2024 For Assessment Year 2018- 19, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The “Cit(A)/Nfac”], Delhi’S Din & Order No. Itba/Nfac/S/250/2023-24/1060727888(1), Dated 09.02.2024, Involving Proceedings Under Section 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Heard Both The Parties. Case Files Perused. 2. We Notice At The Outset That The Assessee’S Cross Objection Herein C.O. No. 40/Del/2024 Goes To The Root Of The Matter Since Challenging Validity Of The Impugned Assessment Itself Framed By The Learned Assessing Authority On 31St May, 2021. This Is For The Precise Reason That The Assessee’S Case Was Taken Up For Scrutiny On The Twin Issues Of Non-Furnishing Of Quantitative Details & “Investments/Advances/Loans” Whereas It Ended Up In Adding An Amount Of Rs.12,59,97,711/- As Unexplained Cash Credits Under Section 68/69A Of The Act, Which Stands Deleted In The Lower Appellate Discussion. This Is What Leaves The Revenue & The Assessee Aggrieved Who Have Filed Their Instant Appeal & Cross Objection; Respectively.

Section 143(2)Section 143(3)Section 68

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 ... recorded for expanding the scope of limited scrutiny, no approval was taken from the PCIT for conversion of the limited scrutiny case to a complete scrutiny case and the order sheet was maintained very perfunctorily. Further, the CBDT has recorded that this gave rise to a very strong suspicion

Griptonite Games India Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle-2(1), Hyderabad

ITA 199/HYD/2022[2017-18]Status: DisposedITAT Hyderabad02 Jun 2025AY 2017-18

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA, HON'BLE (Accountant Member)

For Appellant: Shri S.P.Chidambaram, ARFor Respondent: Shri B. Bala Krishna, CIT-

Section 143(3)Section 144(5)Section 92C

30/11/2017, declaring an income of Rs. 3,69,10,123/-. Subsequently, the case of the assessee company was selected for complete scrutiny under CASS. 4. During the course of the assessment proceedings, the AO, observing that the assessee company had entered into international transactions referred the matter to the Deputy

Baswant Builders and Developers Private Limited, Aurangabad vs. Assistant Commissioner of Income-Tax, Circle 3(1)(1), Mumbai, Aayakar Bhawan

In the result, the appeal of the Assessee stands dismissed

ITA 2730/MUM/2023[2018-19]Status: DisposedITAT Mumbai02 Jun 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Smt Renu Jauhriassessment Year: 2018-19

For Appellant: Represented by Mr. Aaaksh KumarFor Respondent: Represented by Sh

Section 142(1)Section 143(2)Section 14A(2)(b)Section 250

consideration declared its total income at Rs.3,44,05,550/- by filing its original return of income on dated 31.10.2018, which was selected for complete scrutiny under CASS. Consequently, during the assessment proceedings, statutory notices dated

Jile Singh, Faridabad vs. Income Tax Officer, Faridabad

In the result, appeal of the assessee is allowed

ITA 2223/DEL/2025[2017-18]Status: DisposedITAT Delhi02 Jun 2025AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 2223/Del/2025 : Asstt. Year : 2017-18 Jile Singh, Vs Income Tax Officer, H. No. 68, Sotai, Near Mahipal Ward-51(3), Nambardar, Ballabgarh, Faridabad, Faridabad, Haryana-121002 Haryana-121004 (Appellant) (Respondent) Pan No. Fzsps8684G Assessee By: None Revenue By : Sh. Akhilesh Kumar Yadav, Sr. Dr Date Of Hearing: 02.06.2025 Date Of Pronouncement: 02.06.2025 Order

For Appellant: NoneFor Respondent: Sh. Akhilesh Kumar Yadav, Sr. DR

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

Devprabha Construction Private Ltd., Dhanbad vs. PCIT, Dhanbad

In the result, this appeal of the assessee is allowed

ITA 27/RAN/2024[2018-19]Status: DisposedITAT Ranchi30 May 2025AY 2018-19

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay(Virtual Hearing) Devprabha Construction Private Ltd., P.C.I.T., Dev Villa, Behind Radha Swamy Arcade, Dhanbad, Vs. Saraidhela, Dhanbad-828127. Aayakar Bhawan, Luby Pan No. Aaecb 2652 A Circular Road, Dhanbad-826001 (Jharkhand) Appellant/ Assessee Respondent/ Revenue

Section 133(6)Section 143(3)Section 263

engaged in executing mining contracts floated by Bharat Coking Coal Limited (BCCL), Dhanbad. Subsequently, the case of assessee was selected through CASS system for complete scrutiny to examine "business expenses". The Assessing Officer completed assessment under Section 143(3) of the Act vide its order dated 19/04/2021 on a total ... Assessing Officer has completed assessment order without making necessary enquiries or verification in apropos of the issue for which the case was selected for complete scrutiny and therefore, the ld. PCIT set aside the assessment order dated 19/04/2021 on the ground that the assessment order is erroneous