“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

Vardhman Special Steels Ltd., Ludhiana vs. DCIT, Circle-1, Ludhiana

ITA 79/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh20 May 2025AY 2018-19

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 115JSection 142(1)Section 143(2)Section 14ASection 270ASection 36(1)Section 36(1)(iii)Section 57

were paid on book profits of Rs.27,12,91,436/- under the MAT provisions in both returns. The case was selected for complete scrutiny under the E-assessment Scheme, 2019, focusing on issues such as claims under Schedule BP, investments/advances/loans, ICDS compliance, and investment in immovable property. Notices under Section

Kothari Agritech Private Limited, Solapur vs. DCIT Circle 1, Solapur

In the result, appeal of the Assessee is Partly Allowed

ITA 2354/PUN/2024[2015-16]Status: DisposedITAT Pune20 May 2025AY 2015-16

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2354/Pun/2024 िनधा"रण वष" / Assessment Year: 2015-16 Kothari Agritech Private V The Dcit, Limited, S Circle-1, Solapur. 3Rd Floor, Sunplaza, 8516/11, Subhash Chowk, Murarji Peth, Solapur North, Jawaharlal Nehru Vastigrah S.O., Solapur – 413001. Maharashtra Pan: Aadck8017H Appellant/ Assessee Respondent / Revenue Assessee By Mr.Piyush Bafna – Ar Revenue By Shri Ramnath P Murkunde – Dr Date Of Hearing 24/04/2025 Date Of Pronouncement 20/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961; Dated 19.09.2024 For Assessment Year 2015-16. The Assessee Has Raised The Following Grounds Of Appeal :

Section 250

filed Return of Income for A.Y.2015-16 on 30.11.2015 declaring total income of Rs.2,68,05,430/-. The Assessee’s case was selected for complete scrutiny. During the assessment proceedings, Assessee’s Authorised Representative appeared before the Assessing Officer. The Assessing Officer made disallowance u/s.14A of Rs.22,81,994/-. The Assessing

Lahanda Gomarda Samabay Krishi Unnayan Samity Ltd., Uttar Dinajpur vs. ITO Ward-2(4), Raiganj

In the result, the appeal of the assessee is allowed

ITA 131/KOL/2025[2017-18]Status: DisposedITAT Kolkata19 May 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Lahanda Gomarda Samabay Income Tax Officer, Krishi Unnayan Samity Ltd. Ward 2(4), Maharaja Hat, Lahanda, It Office, Sbi Building, Vs. Dist. Uttar Dinajpur, Karnojhora, Raiganj, West West Bengal 733129 Dinajpur, West Bengal-733134 (Appellant) (Respondent) Pan No. Aaaal5359A Assessee By : Shri Soumitra Choudhury & Shri Pranabesh Sarkar, Ars Revenue By : Shri Kapil Monda, Dr Date Of Hearing: 15.05.2025 Date Of Pronouncement : 19.05.2025

For Appellant: Shri Soumitra Choudhury &For Respondent: Shri Kapil Monda, DR

Section 143(2)

copy of which is available at page no.61 of the Paper Book, does not specify whether it is a limited scrutiny or a complete scrutiny or a compulsory manual scrutiny. The ld. AR submitted that the CBDT has issued specific instruction vide instruction no. F. No. 225/157/2017/ITA-II Dated ... other hand submitted that this is a computer- generated notice and the non-mentioning of the fact of either limited or complete scrutiny or compulsory manual scrutiny would not render the issuance of notice u/s 143(2) of the Act as invalid. Therefore, the ground raised by the assessee

Rajagopal Karthikeyan, Erode vs. ITO Ward 2(1), Erode

In the result, appeal filed by the assessee is allowed

ITA 3326/CHNY/2024[2017-18]Status: DisposedITAT Chennai19 May 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri Jagadish

For Appellant: Mr.S.Sridhar, Advocate (Erode)For Respondent: Smt.Gouthami Manivasagam

Section 133(6)Section 143(2)Section 143(3)Section 44ASection 68Section 69A

declaring income of Rs.3,29,620/- for AY 2017-18 claiming income from business and house property. The case was selected for complete scrutiny and notices u/s.143(2) and 142(1) were issued to the assessee calling for various details. Though the assessee responded by his reply

Hcl Comnet Systems and Services Limited, Delhi vs. Deputy Commissioner of Income Tax, /Assessment Unit, Income Tax Department

In the result this ground of appeal is allowed

ITA 4867/DEL/2024[2022-23]Status: DisposedITAT Delhi19 May 2025AY 2022-23

Bench: Ms. Madhumita Roy

Section 143(2)Section 143(3)Section 144BSection 35ASection 37(1)Section 4

income filed on 25.10.2022 has declared Nil income and claimed refund of Rs. 92,53,060. That on 27.6.2023 case was selected for complete scrutiny vide issuance of notice u/s 143(2) of the Act. Ld. AO, from the information available on record, observed that appellant has paid an amount

Meditation Properties Pvt Ltd, New Delhi vs. ITO Ward-16(3), New Delhi

In the result, impugned order is set aside and appeal of the assessee is allowed

ITA 9394/DEL/2019[2015-16]Status: DisposedITAT Delhi19 May 2025AY 2015-16

Bench: Shri Vikas Awasthyआअसं.9394/िद"ी/2019(िन.व. 2015-16) Meditation Properties P. Ltd., Flat No. 10, C-1/2, Model Town, New Delhi 110009 ...... अपीलाथ"/Appellant Pan: Aaacm-1194-N बनाम Vs. Assistant Commissioner Of Income Tax, Appeal-6, Laxmi Nagar, District Centre, ..... "ितवादी/Respondent New Delhi 110092 अपीलाथ" "ारा/ Appellant By : Shri Parveen Kumar, Executive Employee "ितवादी"ारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 19/05/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 19/05/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-6, Delhi (Hereinafter Referred To As 'The Cit(A)') Dated 27.09.2019, For Assessment Year 2015-16. 2. Shri Parveen Kumar, Appearing On Behalf Of The Assessee Submits That The Short Issue In Appeal Is That The Case Of Assessee Was Selected For Limited Scrutiny For The Following Reasons: “(I) There Is A Large Difference In The Opening Stock Of The Current Year & The Closing Stock Of Previous Year In P&L Account As Per Return Of Income; &

For Appellant: Shri Parveen Kumar, Executive EmployeeFor Respondent: Shri Manoj Kumar, Sr. DR

Section 143(2)

opinion that further investigation is require. The AO ought to have taken approval to convert limited scrutiny into complete scrutiny. In light of the fact that the Assessing Officer has travelled beyond his jurisdiction in making inquiries which were not part of the limited scrutiny, the assessment order is without

Julius Ruben, Kochi vs. Assistant Commissioner of Income Tax, Corporate Circle 1(1), Kochi

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

ITA 219/COCH/2025[2015-16]Status: DisposedITAT Cochin16 May 2025AY 2015-16

Bench: Shri George George K, Vice- & Shri Inturi Rama Rao

For Appellant: Sri.A.Gopalakrishnan, CAFor Respondent: Smt.Leena Lal, Senior AR

Section 139(4)Section 143(3)Section 154Section 250Section 40A(3)

return of income was filed u/s.139(4) of the Act on 04.12.2015 declaring total income of Rs.49,02,700. The assessment was selected for complete scrutiny and assessment was passed u/s.143(3) of the Act on 12.12.2017 accepting the returned income declared by the assessee. 4. Thereafter, the AO passed

M/S Essar Shipping Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle 5(1)(1), Mumbai

In the result, ground no. 5 raised by the assessee is dismissed

ITA 4440/MUM/2024[2020-21]Status: DisposedITAT Mumbai16 May 2025AY 2020-21

Bench: Ms. Kavitha Rajagopal, Jm & Shri Omkareshwar Chidara, Am

For Respondent: Shri. Piyush Chaturvedi

Section 143(2)Section 144Section 144C(1)Section 41Section 92B(2)Section 92C

subsequently filed its revised return of income dated 18.11.2021, declaring total income at Rs.4,58,480/-. The assessee's case was selected for complete scrutiny on the following issues. a. High Creditors/Liabilities. b. Investments/Advances/Loans. c. Refund Claim. d. Unsecured Loans. e. ICDS Compliance and Adjustment. f. Expenses incurred for Earning

Himanshu Bhardwaj, Delhi vs. DCIT, Circle-11(2) Range-11, Delhi

In the result, the Assessee’s appeal is dismissed

ITA 5658/DEL/2024[2021-22]Status: DisposedITAT Delhi16 May 2025AY 2021-22

Bench: SHRI MAHAVIR SINGH, HON'BLE (Vice President)

For Appellant: Shri Ganesh Mishra, AdvFor Respondent: Shri Shyam Manohar Singh, Sr. DR

Section 139

that asssessee filed return of income on 29.12.2021, declaring total income of Rs.4,40,550/-. The case of the assessee was scrutinized for complete scrutiny through CASS. The AO noted that the assessee made imports to the tune of Rs. 1,20,19,368/- and total sales turnover

ACIT, Circle-52(1), New Delhi vs. Arun Kumar Gupta, New Delhi

In the result, the appeal of Revenue is dismissed

ITA 4784/DEL/2024[2020-21]Status: DisposedITAT Delhi16 May 2025AY 2020-21

Bench: Shri Pradip Kumar Kedia & Shri Vimal Kumarassessment Year: 2020-21 Acit, Vs. Arun Kumar Gupta, Circle-52(1), 23-25, Bengali Market, New Delhi Delhi Pin 1100 02 Pin: 1100 01 Pan No. Aakpg9900B (Appellant) (Respondent)

For Appellant: Shri C.S. Anand & Ms. VashnaviFor Respondent: Shri Amit Shukla, Sr. DR

Section 133(6)Section 143(3)Section 250Section 68

filed return of income for the assessment year 2020-21 on 30.03.2021 declaring income of Rs.3,10,61,310/-. The case was selected for complete scrutiny under CASS for the reasons that “(i) large value of loss claimed under the head income from house property (Business ITR) and (ii) large

Suman Dahiya, New Delhi vs. ACIT, Circle, Rohtak

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

ITA 3736/DEL/2024[2017-18]Status: HeardITAT Delhi16 May 2025AY 2017-18

Bench: Shri Sunil Kuamar Singh & Shri Brajesh Kumar Singhassessment Year: 2017-18

For Appellant: S/Shri Shantu Jain & Prateek Kumar, AdvocatesFor Respondent: Shri Sanjay Sharma, Sr. DR

Section 143(1)Section 143(2)Section 143(3)Section 250Section 68

declaring total income of Rs.39,65,160/- the return was processed u/s. 143(1) of the Act. The case was selected for complete scrutiny under CASS. Statutory notices u/s. 143(2) and 142(1) of the Act were issued and served upon the assessee asking her to explain

Hcl Software Products Limited, Delhi vs. The Assistant Commissioner of Income Tax, Circle 11(1), Delhi

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

ITA 2704/DEL/2024[2017-18]Status: DisposedITAT Delhi16 May 2025AY 2017-18

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)

For Appellant: Shri Aditya Vohra, AdvocateFor Respondent: Shri Tanay Sharma, Sr. DR

Section 115JSection 143(2)Section 195Section 40Section 9(1)(vii)

assessment year 2017-18 declaring total income of Rs.4,84,79,780/-. The case was selected for scrutiny through CASS for complete scrutiny on the issues mentioned therein and notices under 2 section 143(2) and 142(1) of the Income-tax Act, 1961 (for short ‘the Act’) were issued

DCIT Circle, Hisar vs. Tirupati Matsup Private Limited, Hisar

In the result, the appeal of the Revenue in ITA No

ITA 3326/DEL/2023[2021-22]Status: DisposedITAT Delhi16 May 2025AY 2021-22

Bench: Shri Mahavir Singh & Shri Manish Agarwal

Section 133(6)Section 142(1)Section 143(3)Section 250Section 253Section 69CSection 73(5)

under appeal was filed on 02.03.2022 at an income of INR 47,24,190/-. The case of the assessee was selected under CASS for complete scrutiny. During the course of assessment proceedings, various notices under section 142(1) were issued which were complied with by the assessee. The AO observed

M/S Shree Agrawal Coal India Pvt. Ltd, Nagpur vs. A, C.I.T Cent Cir. 1(2), Nagpur

In the result, assessee’s appeal stands allowed

ITA 180/NAG/2016[2009-10]Status: DisposedITAT Nagpur15 May 2025AY 2009-10

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Sachin V. LuthraFor Respondent: Shri Harshad S. Vengurlekar

Section 132Section 139(1)Section 143(3)Section 153ASection 2(22)(d)Section 2(22)(e)

income under section 139(1) of the Act on 30/09/2009, disclosing total income of ` nil. Subsequently, the assessee’s case was selected for complete scrutiny by the Assessing Officer and high pitched assessment was completed under section 143(3) r/w section 153A of the Act by passing assessment order dated

Hardik Dhirubhai Malaviya, Ahmedabad vs. The ITO, Ward-6(1)(1), Ahmedabad

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

ITA 295/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad15 May 2025AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2017-18

Section 133(6)Section 143(3)Section 234B

filed his return of income for the A.Y. 2017-18 on 30.10.2017 declaring total income of Rs.4,31,560/-. The case was selected for complete scrutiny under CASS. In the course of assessment, the Assessing Officer found that the Hardik Dhirubhai Malaviya vs. ITO Page 2 of 5 assessee

Bala Filling Station, Bharuch vs. ACIT, Circle-1, Bharuch

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

ITA 822/SRT/2024[2017-18]Status: DisposedITAT Surat13 May 2025AY 2017-18

Bench: Shripawan Singh& Shri Bijayananda Prusethआयकरअपीलसं./Ita No.822/Srt/2024 Assessment Year: (2017-18) (Hybridhearing) Bala Filling Station Vs. The Acit, Opp. Geb Substation, Jambusar Circle - 1, Road,Jambusar - 392150, Gujarat Bharuch "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aagfb8418F (अपीलाथ"/Appellant) (""थ"/Respondent)

Section 194C(6)Section 250Section 40Section 68

income of Rs.58,98,190/-. The assessee-firm is engaged in the business of retail trade in petroleum products. The case was selected for complete scrutiny under CASS. After hearing the assessee, the Assessing Officer (in short, ‘AO’) added Rs.10,47,297/-, Rs.4,26,950/-, Rs.3,75,000/- and Rs.6

Waltair Traders, Visakhapatnam vs. Neac, Delhi

ITA 144/VIZ/2024[2018-19]Status: DisposedITAT Visakhapatnam13 May 2025AY 2018-19

Section 133(6)Section 142(1)Section 143(2)Section 194ASection 194CSection 69C

income for the A.Y. 2018-19 on 31.10.2018 admitting a total income of Rs. 2,95,50,830/-. The case was selected for complete scrutiny for examining the business expenses. Thereafter statutory notices under section 143(2) and 142(1) of the Act were issued and served on the assessee

Deputy Commissioner of Income Tax, Circle 2(1)(1), Vadodara, Race Course Cirlce vs. Madhya Gujarat Vij Company Limited, Race Course Cirlce, Vadodara

In the result, the appeal filed by the Revenue is allowed for

ITA 2204/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad09 May 2025AY 2021-22

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokar

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Dr. Sanjay Kumar Lal, CIT-DR

Section 143(3)Section 144BSection 250

assessee filed its return of income on 12.03.2022 declaring Nil income after set-off of brought forward losses. The case was selected for complete scrutiny under CASS and assessment was completed under section 143(3) read with section 144B of the Act. In the said assessment order, the Assessing Officer

Gujarat State Financial Services Ltd., Ahmedabad vs. The Dy. CIT, Circle-2(1)(1), Ahmedabad

In the result, appeal of the assessee is allowed in part

ITA 1226/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad09 May 2025AY 2020-21

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2020-21

Section 135(5)Section 143(3)Section 14ASection 37Section 80GSection 80G(2)(a)

return of income for the A.Y. 2020-21 on 20.01.2021 declaring total income of Rs.493,41,38,980/-. The case was selected for complete scrutiny assessment. In the course of assessment, the Assessing Officer made disallowance of Rs.1,78,71,274/- in respect of donation claimed as deduction under Section

DCIT Circle-3(2)(1), Mumbai vs. Sunjewels Private Limited, Andheri East, Mumbai

In the result, the appeal filed by the assessee and revenue are partly allowed for statistical purpose

ITA 5244/MUM/2024[2014-15]Status: DisposedITAT Mumbai09 May 2025AY 2014-15

Bench: Shri. Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm Sunjewels Private Limited Dy. Commissioner Of Income Tax 116, Sdf-Iv, Seepz, Andheri East, – 3(2)(1), Mumbai Room No. 608, 6Th Floor, Aaykar Mumbai – 400096. Vs. Bhavan, M. K. Road, New Marine Lines, Mumbai – 400020. Pan/Gir No. Aabce3519L (Appellant) : (Respondent) Dy. Commissioner Of Income Tax – Sunjewels Private Limited 3(2)(1), Mumbai 116, Sdf-Iv, Seepz, Andheri East, Room No. 608, 6Th Floor, Aaykar Mumbai – 400096. Vs. Bhavan, M. K. Road, New Marine Lines, Mumbai – 400020. Pan/Gir No. Aabce3519L (Appellant) : (Respondent)

For Appellant: Shri. Ravikanth PathakFor Respondent: Shri. Prashant Barote, Sr. DR

Section 115JSection 143(2)Section 143(3)Section 250Section 72ASection 72A(2)(b)Section 80G

normal provision and book profit of Rs. 36,11,71,961/- u/s. 115JB of the Act. The assessee’s case was selected for complete scrutiny under CASS and notice u/s. 143(2) and 142(1) were duly issued and served upon the assessee. During the assessment proceeding