“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

Sunjewels Private Limited, Mumbai vs. Dy. Commissioner of Income Tax - 3(2)(1), Mumbai

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

ITA 4720/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

Krishna Plantations Pvt. Ltd, Margao vs. Assessment Unit - Income Tax Department, Delhi

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

ITA 199/PAN/2023[2020-21]Status: DisposedITAT Panaji08 May 2025AY 2020-21

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.199/Pan/2023 (A.Y. 2020-21) Krishna Plantations Pvt Ltd, Vs National Faceless 15/1452,Nanuhouse, Varde Assessment Centre, . Valaulikar Road, 2 Floor, F-Ramp, Margoa-403601, Jawaharlal Nehru Goa. Stadium, New Delhi-110003 Pan/Gir No. Aaack6885G (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By Smt.Bhavya Goyal.Ar Revenue By Shri.Ravindra Hattalli Sr.Dr सुनवाई क" तार"ख/Date Of Hearing 20.03.2025 घोषणा क" तार"ख/Date Of Pronouncement 08.05.2025 Order Per Pavan Kumar Gadale ,Jm: The Assesse Has Filed The Appeal Against The Order Of The Nfac/Cit(A) Delhi Passed U/Sec143(3) & U/Sec 250 Of The Act. The Assesse Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Addition Made By The Assessing Officer. 2. At The Time Of Hearing, The Ld.Ar Has Not Pressed The Ground Of Appealno.1 & Made Endorsement; Accordingly This Ground Of Appeal Is Treated As Withdrawn & Is Dismissed.

disclosing a total income of Rs.40,45,110/- and net agricultural income of Rs.63,45,354/- on 5.03.2021. Subsequently, the case was selected for complete scrutiny and notice u/sec143(2) and U/sec142(1) of the Act are issued. The assesee in compliance to various notices has submitted the details

Abroad Vitrified Pvt Ltd, Morbi vs. The Pr. CIT-1, Rajkot

In the result, appeal of assessee is allowed

ITA 144/RJT/2023[2018-19]Status: DisposedITAT Rajkot08 May 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita Nos.144/Rjt/2023 "नधा"रणवष"/Assessment Year : 2018-19

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Sanjay Punglia, CIT-DR

Section 143(3)Section 263Section 68

income for assessment year(AY)) 2018-19, on 29.10.2018, declaring total income at Rs. NIL. Thereafter, the assessee`s case was selected for complete scrutiny through CASS for the reasons to verify (i) Purchases shown in the ITR is less than the invoice value of imports shown in the export

Sh. Sher Singh Meena, Alwar vs. ITO, Ward-2(3), Alwar

In the result, the appeal of the assessee is allowed and addition is directed to be deleted

ITA 361/JPR/2025[2017-18]Status: DisposedITAT Jaipur08 May 2025AY 2017-18

Bench: Shri Gagan Goyal & Shri Narinder Kumarsher Singh Meena, Rajgarh Road, Malakhera, Near Petrol Pump, Alwar 301406 Pan No. Aonpm 2161F ...... Appellant Vs.

For Appellant: Mr. P. C. Parwal, C.A., Ld. ARFor Respondent: Mrs. Swapnil Parihar, JCIT, Ld. DR

Section 115BSection 250Section 69Section 69A

agricultural pipes and boring pipes for submersible pumps in the name of M/s. Shera Pipe Agencies. The case of the assessee was selected for complete scrutiny under the CASS on the issue of Cash deposits during the demonetization period. Throughout the assessment proceedings other than seeking adjournment once

ACIT, Central Circle-2, Jaipur vs. Unimax Buildestate Pvt Ltd, Jaipur

In the result, the appeal of the revenue as well as cross objection of the

ITA 103/JPR/2024[2014-15]Status: DisposedITAT Jaipur08 May 2025AY 2014-15

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Swapnil Parihar, JCIT-DR

Section 143(2)Section 250

order passed by the Ld AO making addition of reason other than the reason of limited scrutiny without following the procedure to convert into complete scrutiny, is bad in law. The Ld CIT (A) after considering the facts of the case, remand report from the Ld AO, order sheet ... where-in, the Ld AO has submitted vide remand report dated 06-10-2020 that the issue raised i.e. 'conversion of limited scrutiny to complete scrutiny', not relevant to examination of additional evidence. (d) Para 4.6 of the order – (at Page no 24 & 25 of paper book) where

Kony Inc, United States of America vs. Deputy Commissioner of Income Tax, International Taxation 1(2), Chennai, Tamil Nadu

In the result, the appeal filed by the assessee is allowed and the stay petition filed by the assessee is dismissed

ITA 185/CHNY/2025[2022-23]Status: DisposedITAT Chennai08 May 2025AY 2022-23

Bench: Shri George George K & Shri Jagadish

For Appellant: Shri R. Sivaraman, AdvocateFor Respondent: Shri V. Justin, CIT

Section 143(2)Section 4

filed on 04.11.2022 declaring total income of Rs.30,31,692/- and claimed refund of Rs.1,30,87,130/-. The assessment was selected up for complete scrutiny under CASS and notice u/s.143(2) of the Act was issued on 31.05.2023. On perusal of the financials filed by the assessee company

Raghuvirsinh Harishchandrasinh Zala, Halvad vs. ITO, WD-4, Morbi

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

ITA 298/RJT/2024[2017-18]Status: DisposedITAT Rajkot07 May 2025AY 2017-18

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

For Appellant: Shri Viral Vajani, Ld. A.RFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 143(1)Section 143(3)Section 69

return of income filed was processed u/s. 143(1) of the act without any modification. Thereafter, the case has been selected for complete scrutiny under CASS for examination of reason: “Large agricultural income shown in ITR and large cash deposit during demontisation.” Subject to the above remarks and considering

Thakkar Mukeshbhai Keshavlal, HUF, Ahmedabad vs. The Income Tax Office, Ward-3(3)(5), Ahmedabad

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

ITA 1498/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad07 May 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2017-18 Thakkar Mukeshbhai Keshavlal Huf Ito, Ward-3(3)(5) 456, 45Th Floor, Titanium City Centre Vs. Vejalpur, Ahmedabad. Nr.Sachin Tower Satellite Ahmedabad 380 015. Pan : Aaaht 1750 N (Applicant) (Responent) : Shri Rupesh R. Shah, Ar Assessee By Revenue By : Smt.Trupti Patel, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 06/05/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/05/2025

For Respondent: Smt.Trupti Patel, Sr.DR

Section 115BSection 143(1)Section 143(3)Section 250Section 271ASection 69A

declaring total income of Rs.5,63,300/-, which was processed under section 143(1) of the Act. The case was selected for complete scrutiny under Computer Assisted Scrutiny Selection (CASS) with the reason flagged as “abnormal increase in cash deposits during the demonetization period as compared to pre- demonetization period

Akshay Kumar Rungta, Bangalore vs. Income Tax Officer, Ward 2(1), International Taxation

In the result, appeal filed by the assessee is allowed as per above terms

ITA 66/BANG/2024[2015-16]Status: DisposedITAT Bangalore07 May 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.66/Bang/2024 Assessment Year :2015-16

For Appellant: Shri. Ravishankar S. V, AdvocateFor Respondent: Ms. Neha Sahay, JCIT(DR)(ITAT), Bangalore

Section 10(38)Section 143(3)Section 144CSection 147Section 147rSection 148Section 151Section 153Section 153CSection 250

Assessment Year 2015-16 was completed on 28.12.2017 accepting the return income of Rs.7,63,040/-. The case was selected for complete scrutiny under CASS to verify any suspicious sale transaction in shares (penny stock). Assessment Order under section 143(3) of the Act was passed on 28.12.2017 by accepting ... reiterated the submissions made before the lower authorities and further submitted that this is a complete change of opinion. The case was selected for complete scrutiny and AO issued notices on various dates under section 142(1) of the Act on 20.02.2017, 12.11.2017 and 13.10.2017 and the reason or selection

Shri. Anantula Vijay Mohan, Hyderabad vs. Deputy Commissioner of Income Tax, Circle-6(1)(1), Bangalore

ITA 2060/BANG/2024[2017-18]Status: DisposedITAT Bangalore07 May 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

Section 143(3)Section 250

Central Board of Direct Taxes ['CBDT' for brevity] to expand the scope of a limited scrutiny or to convert it into a complete scrutiny. 3. The variations made in the assessment order under section 143(3), beyond the scope of limited scrutiny of the Appellant, are without jurisdiction ... computation of income and accordingly the AO can verify all the heads of income declared in the return because of which refund results like complete scrutiny. Hence, the AO is justified to verify the issue of set off of short term capital loss claimed against short term capital gain

Anantula Vijay Mohan, Hyderabad vs. Deputy Commissioner of Income Tax, Circle-6(1)(1), Bangalore

ITA 2059/BANG/2024[2016-17]Status: DisposedITAT Bangalore07 May 2025AY 2016-17

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

For Respondent: Sri Padma Khincha, A.R

Section 143(3)Section 250

Rajesh Kumar Poonia, Jhunjhunu vs. Assistant Commissioner of Income Tax, Circle- Jhunjhunu, Jhunjhunu

In the result, both the appeals of the assessee are allowed

ITA 623/JPR/2024[2016-17]Status: DisposedITAT Jaipur06 May 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Vedant Agrawal, Adv. (V.C)For Respondent: Sh. Anup Singh, Add. CIT-DR

Section 131Section 133ASection 142(1)Section 143(2)Section 143(3)Section 145(3)

matter was required to be examined thoroughly beyond the reasons of the 'limited scrutiny. Accordingly, the case was converted from limited scrutiny criteria to complete scrutiny after obtaining necessary approval of the Pr. Commissioner of Income Tax-3, Jaipur vide her letter No. 2282 dated 10/12/2018. Rajesh Kumar Poonia ... ACIT 3.4 After conversion of the case from 'limited scrutiny to complete scrutiny a notice u/s 142(1) of the IT Act, 1961 was issued to the assessee along with a detailed questionnaire/ show cause dated 10/12/2018. In response to this the assessee furnished his reply electronically on 14/12/2018

Rajesh Kumar Poonia, Jhunjhunu vs. Assistant Commissioner of Income Tax, Jhunjhunu

In the result, both the appeals of the assessee are allowed

ITA 611/JPR/2024[2017-18]Status: DisposedITAT Jaipur06 May 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Vedant Agrawal, Adv. (V.C)For Respondent: Sh. Anup Singh, Add. CIT-DR

Section 131Section 133ASection 142(1)Section 143(2)Section 143(3)Section 145(3)

K.M.Sugar Mills Limited, Kanpur vs. ACIT Circle2(2)(1), Kanpur

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

ITA 599/LKW/2024[2016-17]Status: HeardITAT Lucknow06 May 2025AY 2016-17

Bench: Shri Kul Bharat & Shri Nikhil Choudharyassessment Year: 2016-17

For Appellant: Shri Pankaj Shukla, AdvFor Respondent: Shri R. K. Agarwal, CIT(DR)

Section 143(1)Section 143(2)Section 37

return was processed u/s 143(1) of the Income Tax Act, 1961 (hereinafter referred as “the Act”). Thereafter, the case was selected for complete scrutiny. The Assessing Officer, while framing assessment made various additions in the income of the assessee i.e. out of disallowance of CSR expenditure of Rs.20

V R Auto Services, Nashik vs. ACIT, Circle 1, Nashik

In the result, appeal of the assessee is allowed

ITA 42/PUN/2025[2017-18]Status: DisposedITAT Pune06 May 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.42/Pun/2025 Assessment Year : 2017-18

For Appellant: Shri Pramod ShingteFor Respondent: Shri Ganesh B Budruk

Section 115BSection 143Section 250Section 69A

Authorised Dealer of Reliance Industries Ltd. Income of Rs.17,69,830/- declared in the return of income e-filed on 30.10.2017. Case selected for complete scrutiny followed by validly serving of statutory notices under the Act. During the course of assessment proceedings, ld. AO noticed that total cash deposit during

Shelke Constructions and M/S Yash Builders and Cunstruction Co, Pune vs. ITO Ward 1(1), Jalgaon

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 223/PUN/2025[2018-19]Status: DisposedITAT Pune06 May 2025AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.222 & 223/Pun/2025 Assessment Year : 2018-19

For Appellant: Shri Digamber SurwaseFor Respondent: Shri Ganesh B Budruk

Section 144Section 270A

partnership firm, furnished its income-tax return for A.Y. 2018-19 on 31.10.1980 declaring income of Rs.1,43,740/-. Case selected for complete scrutiny for the Contract receipts or Fees. Assessee failed to appear before the ld. AO even after proper notices of hearing were issued. However, the reason

Shelke Constructions and M/S Yash Builders and Cunstruction Co, Jalgaon vs. ITO Ward 1(1), Jalgaon

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 222/PUN/2025[2018-19]Status: DisposedITAT Pune06 May 2025AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.222 & 223/Pun/2025 Assessment Year : 2018-19

For Appellant: Shri Digamber SurwaseFor Respondent: Shri Ganesh B Budruk

Section 144Section 270A

Airawat Developers Pvt Ltd, Pune vs. ITO, Ward 1(1), Pune

In the result, the appeal filed by the assessee in ITA

ITA 22/PUN/2025[2016-17]Status: DisposedITAT Pune06 May 2025AY 2016-17

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1898/Pun/2024 िनधा"रण वष" / Assessment Year : 2016-17 Airawat Developers Pvt. Ltd., Vs. Ito, Ward-1(1), Pune. Office No.U5/6, Runwal Platinum Plot No.3-B, Ramnagar Colony, Bavdhan, Pune- 411022. Pan : Aaccn3380M Appellant Respondent आयकर अपील सं. / Ita No.22/Pun/2025 िनधा"रण वष" / Assessment Year : 2016-17 Airawat Developers Pvt. Ltd., Vs. Ito, Ward-1(1), Pune. Office No.U5/6, Runwal Platinum Plot No.3-B, Ramnagar Colony, Bavdhan, Pune- 411022. Pan : Aaccn3380M Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Amol Khairnar Date Of Hearing : 12.02.2025 Date Of Pronouncement : 06.05.2025 आदेश / Order Per Vinay Bhamore, Jm: The Above Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 29.07.2024 & 08.11.2024 Passed By Ld. Cit(A)/Nfac Which, In Turn, Have Arisen From Assessment Order Dated 29.12.2018 Passed U/S 143(3) & Rectification Order Dated 11.03.2019 Passed U/S 154 R.W.S. 143(3) Of The It Act For The Assessment Year 2016-17 Respectively. 2. Since Both The Above Captioned Appeals Relate To The Same Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1898/Pun/2024 For Adjudication.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amol Khairnar

Section 142(1)Section 143(3)Section 154Section 43C

real estate construction business and has furnished its return of income by disclosing loss of Rs.45,44,599/-. The case was selected for complete scrutiny. Notices u/s 142(1) and 143(2) were issued and in compliance to the same assessee company has submitted its reply. The Assessing Officer found

Airawat Developers Private Limited, Pune vs. ITO Ward 1(1), Pune

In the result, the appeal filed by the assessee in ITA

ITA 1898/PUN/2024[2016-17]Status: DisposedITAT Pune06 May 2025AY 2016-17

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amol Khairnar

Section 142(1)Section 143(3)Section 154Section 43C

Tera Unemployed Engineers Co-Operative Society Ltd., Coochbehar vs. ITO, Ward-2(2), Coochbehar

In the result, the appeal of the assessee is allowed

ITA 674/KOL/2024[2014-15]Status: DisposedITAT Kolkata06 May 2025AY 2014-15

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Tera Unemployed Engineers Co-Operative Society Ltd. Ito, Ward-2(2) Girish Bhawan, Magazine Road It Building, Biswan Singha Road, Vs. Extension, Coochbehar, West Coochbehar,West Bengal-736101 Bengal, 736101 (Appellant) (Respondent) Pan No. Aaalt0515B Assessee By : Shri Soumitra Choudhury & Shri Pranabesh Sarkar, Ars Revenue By : Shri S.B. Chakraborthy, Dr Date Of Hearing: 07.04.2025 Date Of Pronouncement : 06.05.2025

For Appellant: Shri Soumitra Choudhury &For Respondent: Shri S.B. Chakraborthy, DR

Section 143(2)

copy of which is enclosed at page no.3 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, additional ground raised by the assessee