“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

Mace Project and Cost Management Private Limited, Gurgaon vs. DCIT, Circle 16(1), Delhi

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

ITA 955/DEL/2023[2017-18]Status: DisposedITAT Delhi26 May 2025AY 2017-18

Bench: Shri Shamim Yahya & Shri Vimal Kumarassessment Year: 2017-18 Mace Project & Cost Vs. Dcit, Management Private Limited, Circle 16(1), 01A171 & 01A172, New Delhi Platina Tower, M.G. Road, Sector 28, Gurgaon-122002 Haryana Pin 122002 Pan No. Aahcm0132D (Appellant) (Respondent)

For Appellant: Shri Manish Garg, CAFor Respondent: Shri Choudhary, Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 250Section 40(1)(i)

Notice under Section 143(2) of the Act was issued on 20.08.2018 was issued. Notices under Section 142(1) along with questionnaire relating to complete scrutiny were issued to the assessee. The assessee furnished relevant details/documents through e-filing portal and the case was completed under e- proceedings. On completion

Hyderabad Metropolitan Development Authority, Hyderabad vs. DCIT, Exemption Circle-1(1), Hyderabad

The appeal of the revenue is partly allowed for statistical

ITA 581/HYD/2024[2020-21]Status: DisposedITAT Hyderabad23 May 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.581/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2020-21) M/S. Hyderabad Metropolitan Development Authority, Hyderabad. Pan:Aaalh0058D …..Appellant. Vs. Asst. Commissioner Of Income Tax (Exemptions), Circle-1(1), Hyderabad. …..Respondent. आ.अपी.सं /Ita No.568/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2020-21) Asst. Commissioner Of Income Tax (Exemptions), Circle-1(1), Hyderabad. …..Appellant. Vs. M/S. Hyderabad Metropolitan Development Authority, Hyderabad. …..Respondent.

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Ms. M. Narmada, CIT-DR

Section 143(2)Section 143(3)

contra, the Learned Department Representative (“Ld. DR”) submitted that, although the case was selected for some specific reasons, it was a case of complete scrutiny. Under complete scrutiny assessment, the Ld. AO has jurisdiction to examine all the aspects of the ROI, including verification of receipts, expenditure and claim made ... assessee. The verification is not restricted under the complete scrutiny only to the specified reasons for ITA Nos.581 & 568/Hyd/2024 6 selection. The Ld. DR prayed before the bench to reject the technical argument advanced by the assessee. 7.3 We have heard the rival contentions and also gone through the record

ACIT (Exemptions), Circle-1(1), Hyderabad vs. Hyderabad Metropolitan Development Authority, Hyderabad

The appeal of the revenue is partly allowed for statistical

ITA 568/HYD/2024[2020-21]Status: DisposedITAT Hyderabad23 May 2025AY 2020-21

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Ms. M. Narmada, CIT-DR

Section 143(2)Section 143(3)

Gasifpower Tech Private Limited, Thane West vs. Income Tax Officer, Thane West

ITA 1740/MUM/2025[2015-16]Status: DisposedITAT Mumbai23 May 2025AY 2015-16

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

For Appellant: Shri B.N. Rao, CAFor Respondent: Shri Rajesh Sakhardande, Sr. DR

Section 250Section 56(2)(viib)

return of income for AY 2015-16 on 30.09.2015 declaring a total Loss of Rs. 30,59,040/-. Subsequently, the case was selected for complete scrutiny in order to verify large share premium on issue of shares during the year. During the course of assessment proceedings the Assessing Officer

Shri Ganesh Co Op Credit Soc. Ltd, Mumbai vs. ITO, Ward 31(1)(1), Mumbai

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

ITA 6876/MUM/2024[2017-18]Status: DisposedITAT Mumbai23 May 2025AY 2017-18

Bench: MS. KAVITHA RAJAGOPAL (Judicial Member), SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri. Vijay JoshiFor Respondent: Shri. Anil Gupta - SR. DR

Section 143(2)Section 143(3)Section 194A(3)(v)Section 250Section 263Section 80P(2)(d)

after claiming deduction under Chapter VI-A of the Act amounting to Rs. 15,19,506/-. The assessee’s case was selected for complete scrutiny under CASS and notices u/s. 143(2) and 142(1) of the Act were duly issued and served upon the assessee. The learned Assessing Officer

Assistant Commissioner of Income Tax, Delhi vs. Technosys Integrated Solutions Pvt Ltd, Delhi

In the result, Cross-Objection filed by the Assessee is partly allowed for statistical purpose

ITA 3356/DEL/2024[2020-21]Status: DisposedITAT Delhi23 May 2025AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalassistant Commissioner Of Vs. Technosys Integrated Income Tax, Room Number, Solutions Pvt. Ltd. 192A, First Floor, C. R. Karol Bagh, Rameshwari Building, Ito, New Delhi Naharu Nagar, Central Delhi, New Delhi Pan: Aaecm4997P Appellant Respondent C.O No. 98/Del/2024 (A.Y. 2020-21) In (Ita No. 3356/Del/2024 (A.Y. 2020-21)

turnover of Rs. 251,97,81,810/- and total income at Rs. 12,50,95,220/-. The case of the Assessee was selected for ‘Complete Scrutiny’ and an assessment order came to be passed on 28/09/2022 by computing income of the Assessee at Rs. 17,44,53,906/- by making ... Solutions 4. The Ld. Department's Representative taken us through the assessment order and contended that the case of the Assessee was selected for ‘Complete Scrutiny’, however, the Ld. CIT(A) erroneously relied on the CBDT Circular dated 08/09/2010, which is applicable to the scrutiny on the basis of data

Dlf Home Developers Limited, New Delhi vs. Principal Commissioner of Income Tax, Delhi-1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 2585/DEL/2024[2019-20]Status: DisposedITAT Delhi23 May 2025AY 2019-20

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2019-20] Dlf Home Developers Limited, Vs Pr.Cit, 9Th Floor, Dlf Centre, Sansad Delhi-1, Marg, New Delhi-110001. New Delhi Pan-Aaccd0037H Appellant Respondent Appellant By Shri R.S.Singhvi, Ca & Shri Satyajeet Goel, Ca Respondent By Shri Surender Pal, Cit Dr Date Of Hearing 19.03.2025 Date Of Pronouncement 23.05.2025

Section 143(3)Section 263

paperbook].” 26. On the other hand, Ld.CIT DR has submitted that if the case of the assessee was selected for complete scrutiny wherein the AO failed to make necessary inquiries and has not analyzed the details of rental income shown, standard deduction claimed and issue of depreciation. He therefore, submits

M/S. Simero Vitrified P. Ltd., Morbi vs. The Pr. CIT-3, Rajkot

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

ITA 276/RJT/2019[2016-17]Status: DisposedITAT Rajkot22 May 2025AY 2016-17

Bench: Us Is A Private Limited Company & Engaged In The Business Of Manufacturing Of Vitrified Tiles. The Return Of Income Has Been E-Filed By The Assessee, On 10/09/2016 For Assessment Year (A.Y.) 2016-17, Reporting Loss Of Rs. 5,68,00,829/-, Which Was Later Revised On 09/03/2018, Declaring Total Loss Of Rs. 13,97,40,413/-, Claiming Investment Allowance U/S 32Ac Of The Income Tax Act. The Case Has Been Selected For Complete Scrutiny (Cass) Specifically To Examine The Followings: 1) Whether Outward Foreign Remittance Is From Disclosed Sources & Appropriate Withholding & Reporting Obligation Have Been Complied With; 2) Whether Investment & Income Relating To Properties Are Duly Disclosed; 3) Whether Receipt Of Foreign Remittance Has Been Correctly Offered For Tax And, 4) Whether Sundry Creditors Are Genuine. 4. The Assessment Order U/S 143(3) For The Assessment Year (A.Y.) 2016-17 Was Passed By Dcit, Morbi Circle, Morbi, Being The Assessing Officer (Ao), On 21/12/2018, Allowing The Loss Claimed Of Rs. 13,97,40,413/- To Be Carry Forward To Subsequent Years. 2

Section 143(3)Section 263Section 32ASection 68

total loss of Rs. 13,97,40,413/-, claiming Investment Allowance u/s 32AC of the Income Tax Act. The case has been selected for Complete Scrutiny (CASS) specifically to examine the followings: 1) Whether outward foreign remittance is from disclosed sources and appropriate withholding and reporting obligation have been complied

Sh Infratech Pvt.Ltd, Sultanpur vs. Dy. CIT Circle, Faizabad

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

ITA 203/LKW/2024[2017-18]Status: DisposedITAT Lucknow22 May 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2017-18 Sh Infratech Private Limited V. The Dcit 16/12, Industrial Area Circle, Faizabad Jagdishpur, Sultanpur Sultanpur - New Tan/Pan:Aancs6252J (Appellant) (Respondent) Appellant By: Shri P. K. Kapoor, C.A. Respondent By: Shri Amit Kumar, D.R. Date Of Hearing: 06 05 2025 Date Of Pronouncement: 22 05 2025 O R D E R

For Appellant: Shri P. K. Kapoor, C.AFor Respondent: Shri Amit Kumar, D.R

Section 144Section 69A

year under consideration on 31.03.2018, declaring a total income of Rs.1,72,03,780/-. The case of the assessee was selected for complete scrutiny under CASS for verification of “Large turnover shown in ITR but Audit Report (3CD Form) not filed”. The Assessing Officer (AO) issued various statutory notices

Kanubhai Rahabhai Bharvad, Vadodara vs. The Dy.CIT, Circle-2(1)(1), Vadodara

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

ITA 171/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad22 May 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Hemant Suthar, ARFor Respondent: Shri Rignesh Das, CIT-DR

Section 133(6)Section 143(3)Section 69A

return of income for the A.Y. 2017-18 on 31.03.2018 declaring income of Rs.32,78,060/-. The case of the assessee was selected for complete scrutiny under CASS. In the course of assessment, no compliance was made by the assessee. From SFT data available in ITBA portal

ITO Mehsana Ward 5 Kadi, Kadi vs. The Gozaria Peoples Co Operative Credit Society Limited, Gozaria

The appeal stands dismissed

ITA 1820/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad22 May 2025AY 2020-21

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2020-21 Ito, Mehsana Ward-5 The Gozaria Peoples Co-Operative Kadi. Vs Credit Society Ltd. 2, Main Bazar At Gozariya Ta. Mehsana 383 825 Gujarat. Pan : Aaajt 1283 G (Applicant) (Responent) : Shri B.K. Patel, Ar Assessee By Revenue By : Shri Durga Dutt, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 02/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 22/05/2025 आदेश आदेश/O R D E R आदेश आदेश

For Respondent: Shri Durga Dutt, CIT-DR

Section 143(3)Section 270ASection 40A(7)Section 68Section 80P(2)(a)Section 80P(2)(d)

income of Rs.1,54,560/- and claimed deduction under section 80P(2)(a)(i) amounting to Rs.89,91,830/-. The return was selected for complete scrutiny under CASS. During the assessment proceedings, the assessee failed to comply with notices issued under sections 142(1) and 143(2) as well

Cooper Corporation Private Limited, Satara vs. National Eassessment Centre, Not Known

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

ITA 212/PUN/2025[2020-21]Status: DisposedITAT Pune22 May 2025AY 2020-21

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Cooper Corporation Pvt. Ltd. Dcit, Satara Circle, Satara M60-1, Nariman House, Additional Vs. Midc, Vijay Nagar, Gojegaon B.O., Satara – 415004 Pan: Aaacc9687J (Appellant) (Respondent) Assessee By : Shri Krishna V Gujarathi Department By : Shri Amol Khairnar Cit-Dr Date Of Hearing : 14-05-2025 Date Of Pronouncement : 22-05-2025 O R D E R

For Appellant: Shri Krishna V GujarathiFor Respondent: Shri Amol Khairnar CIT-DR

Section 143(2)Section 35

which was revised on 29.03.2021 declaring taxable income of Rs.40,23,86,800/-. The case of the assessee was selected for complete scrutiny under CASS. Accordingly, statutory notices u/s 143(2) and 142(1) of the Act were issued and served on the assessee in response to which

Narayana Rao Hebri, Sagar vs. The Assistant Commissioner of Income Tax, Circle-1, Shivamogga

In the result, the appeal of assessee is partly allowed

ITA 2051/BANG/2024[2017-18]Status: DisposedITAT Bangalore22 May 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Tata Krishna, AdvocateFor Respondent: Shri V. Parithivel, Jt.CIT(DR)(ITAT), Bengaluru

Section 115BSection 143(3)Section 144Section 68

cash during demonetization period. It is not the case of the parties that anytime the Limited scrutiny was converted into Page 18 of 22 Complete scrutiny case. Therefore, the ld AO was precluded in examining any other issue other than the issue of ‘ examination of payment of tax in cash ... jurisdiction by charging higher rates of tax and surcharge on the above survey disclosure without converting the case of scrutiny from limited scrutiny to complete scrutiny. Accordingly, ld. AO is not correct to the extent of levy of Higher rate of tax u/s 115 BBE and consequent surcharge

Dy. Commissioner of Income Tax-1(1), Bhilai vs. Rashmi Lakhotia, Durg

Appeal of the assessee is allowed for statistical purposes, in terms of over aforesaid observations

ITA 244/RPR/2025[2020-21]Status: DisposedITAT Raipur21 May 2025AY 2020-21

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 244/Rpr/2025 (िनधा"रण वष" Assessment Year: 2020-21)

For Appellant: Shri Yogesh Sethia, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 143(3)Section 250Section 69Section 69A

other sources. The assessee filed her ITR on 14.01.2021, declaring total income of Rs.35,44,15,730/-. The case of assessee was selected for complete scrutiny through ‘CASS’ on the following reasons: (i) Expenditure of personal nature, (ii) High creditors / Liabilities, (iii) Unsecured loans. During the assessment proceedings, deliberating

Himalayan Endeavour Pvt. Ltd., Kolkata vs. ACIT, Circle-1, Siliguri

In the result, all the three appeals of the assessee are partly allowed for statistical purposes

ITA 237/KOL/2025[2017-18]Status: DisposedITAT Kolkata21 May 2025AY 2017-18

Bench: Shri George Mathan & Shri Sanjay Awasthi

For Appellant: Shri Subash Agarwal, AdvocateFor Respondent: Ms. Roma Chaudhary, Sr. DR

Section 143(3)Section 14A

examination. These facts lead to a clear bonafide belief of the revenue about the malafide intention of the assessee to prevent a clear and complete scrutiny of its account in a similar modus operandi as was done during the course of scrutiny for the A.Y. 13-14. The percentage

Himalayan Endeavour Pvt. Ltd., Kolkata vs. DCIT, Circle-1, Siliguri

In the result, all the three appeals of the assessee are partly allowed for statistical purposes

ITA 236/KOL/2025[2014-15]Status: DisposedITAT Kolkata21 May 2025AY 2014-15

Bench: Shri George Mathan & Shri Sanjay Awasthi

For Appellant: Shri Subash Agarwal, AdvocateFor Respondent: Ms. Roma Chaudhary, Sr. DR

Section 143(3)Section 14A

Himalayan Endeavour Pvt. Ltd., Kolkata vs. ACIT, Circle-1, Siliguri

In the result, all the three appeals of the assessee are partly allowed for statistical purposes

ITA 235/KOL/2025[2013-14]Status: DisposedITAT Kolkata21 May 2025AY 2013-14

Bench: Shri George Mathan & Shri Sanjay Awasthi

For Appellant: Shri Subash Agarwal, AdvocateFor Respondent: Ms. Roma Chaudhary, Sr. DR

Section 143(3)Section 14A

Subhash Chander, Hisar vs. Principal Commissioner of Income Tax, Rohtak

In the result, appeal of the assessee is allowed

ITA 2356/DEL/2024[2019-20]Status: DisposedITAT Delhi21 May 2025AY 2019-20

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 2356/Del/2024 : Asstt. Year : 2019-20 Subhash Chander, Vs Pcit, House No. 1476, Vivek Nagar, Rohtak, Hisar, Haryana-125001 Haryana-124001 (Appellant) (Respondent) Pan No. Axlpc0177G Assessee By : Sh. Kuldip Khera, Ca Revenue By : Sh. Jitender Singh, Cit-Dr Date Of Hearing: 21.05.2025 Date Of Pronouncement: 21.05.2025 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2019-20, Arises Against The Pcit, Rohtak’S Din & Order No. Itba/Rev/F/Rev5/2023–24/1062890142(1) Dated 19.03.2024, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Kuldip Khera, CAFor Respondent: Sh. Jitender Singh, CIT-DR

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(viii)Section 57

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

Mahendra Prasad, East Champaran vs. Assessment Unit, Itd, Delhi

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

ITA 717/PAT/2024[2021-22]Status: DisposedITAT Patna20 May 2025AY 2021-22

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 139(1)Section 142(1)Section 144Section 145(3)Section 24Section 250Section 80C

Subsequently the case of the assessee was selected under Computer Assisted Scrutiny Selection (CASS) for complete scrutiny. On perusal of the details, the Assessing Officer (hereinafter referred to as Ld. 'AO') found that the assessee had declared total sales of Rs. 2,03,22,297/- and had debited purchases

Gyanesh Chandra Srivastava, Jaipur vs. ITO Ward 1(3), Jaipur

In the result, appeal of the assessee is allowed

ITA 1516/JPR/2024[2018-19]Status: DisposedITAT Jaipur20 May 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Ashok Kumar Gupta, AdvocateFor Respondent: Mrs. Swapnil Parihar, JCIT-DR

Section 10Section 142(1)Section 143(2)Section 143(3)Section 250

income for the year under consideration on 23.08.2018 declaring total income of Rs. 17,48,490/-. The case of the assessee was selected for Complete Scrutiny 3 Shri Gyanesh Chandra Srivastava, Jaipur. assessment under the E-assessment Scheme, 2019 on the issue of (i) Salary Income and (ii) Refund Claim