“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

Hind Ceramics Pvt. Ltd., Kolkata vs. DCIT, Circle - 10(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 610/KOL/2024[2017-18]Status: DisposedITAT Kolkata06 May 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Soumitra Choudhury &For Respondent: Shri Huidrom Robindro Singh, DR

Section 143(2)Section 234BSection 24(1)

that the notice u/s 143(2) of the Act issued to the assessee did not specify whether it was a limited scrutiny or a complete scrutiny or a compulsory manual scrutiny. The ld. AR submitted that the CBDT has issued specifically provided 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

Hind Ceramics Pvt. Ltd., Kolkata vs. DCIT, Circle - 10(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 608/KOL/2024[2012-13]Status: DisposedITAT Kolkata06 May 2025AY 2012-13

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Soumitra Choudhury &For Respondent: Shri Huidrom Robindro Singh, DR

Section 143(2)Section 234BSection 24(1)

Hipe Infrastructure Projects LLP, Bangalore vs. Assistant Commissioner of Income Tax, Circle-7(1)(1), Bangalore

In the result, appeal filed by the assessee is allowed

ITA 1338/BANG/2024[2018-19]Status: DisposedITAT Bangalore06 May 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year :2018-19

For Appellant: Shri. Narendra Kumar Jain, AdvocateFor Respondent: Shri. Sunil Kumar Agarwal, CIT(DR)(ITAT), Bangalore

Section 143(2)Section 68Section 69

appellate Tribunal to decide the appeal according to law. 2. Briefly stated, the facts of the case are that the case was selected for complete scrutiny assessment under the e-Assessment Scheme, 2019. The assesseefiled return of income on 03.10.2018 showing loss of Rs.45,711/- and notice under section

Shashi Prabha Singhania, Neemuch vs. Income-Tax Officer Neemuch, Neemuch

ITA 800/IND/2024[2018-19]Status: DisposedITAT Indore05 May 2025AY 2018-19

Bench: Bhagirath Mal Biyani & Shri Paresh M Joshi

Section 142(1)Section 143(2)Section 250Section 253Section 44ASection 80CSection 80D

corresponding previous year period is from 01.04.2017 to 31.03.2018. 2. FACTUAL MATRIX 2.1 That the case of the assessee was selected for complete scrutiny assessment order e-assessment scheme, 2019 on the following issues:- S.No. Issues (i) Refund claim (ii) Capital Gain/Income on sale of property 2.2 That the assessee ... total income to Rs.6,74,520/- after claiming deduction of Rs.1,82,066/- under Chapter VI-A. 2.3 That the case was selected for complete scrutiny. Since the assessee had filed her return of Income for AY-2018-19, a notice u/s 143(2) of the I.T Act was issued

Dharmessh Shah, Ahmedabad vs. The ITO, Ward-1, Patan

In the result the appeal of the assessee is partly allowed

ITA 439/AHD/2025[2019-2020]Status: DisposedITAT Ahmedabad05 May 2025AY 2019-2020

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2019-20 Dharmessh Shah The Ito, Ward-1 A-301, Vasantkunj Vs Patan. Garden Residency Sanjivan Road Paldi, Ahmedabad. Pan : Aelps 5203 A (Applicant) (Responent) : Shri Kunal T. Sanghavi, Ar Assessee By : Shri Prathvij Raj Meena, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 30/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 05/05/2025 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri Prathvij Raj Meena, CIT-DR

Section 147Section 148Section 148ASection 271ASection 69C

raised by the AR during the hearing was that in the assessee’s own case for A.Y. 2021–22, the return was selected for complete scrutiny under CASS, specifically for the reason of “Purchase from High Risk Biller (CBIC)”, covering vendors similarly flagged as in the current case

The Secondary Teachers Co-Operative Credit Society Limtied, Dharwad vs. Income Tax Officer, Ward-1(1), Hubli

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

ITA 2383/BANG/2024[2021-22]Status: DisposedITAT Bangalore05 May 2025AY 2021-22

Bench: Shri Waseem Ahmedassessment Year: 2021-22

For Appellant: Shri Atul Alur, AdvocateFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept

Section 57(2)Section 80PSection 80P(2)(a)Section 80P(2)(d)

after claiming deduction under section 80P of the Act for Rs. 43,87,271/- only. 4. The case of the assessee was selected for complete scrutiny under CASS. During the assessment proceedings, the AO collected details such as copy of registration certificate, byelaws, P&L Account, Balance sheet, bank statements

Wns Global Services Private Limited, Mumbai vs. Asessment Unit, National Faceless Assessment Centre, New Delhi

In the result, the appeal of the assessee bearing ITA No

ITA 4432/MUM/2024[AY 2020-2021]Status: DisposedITAT Mumbai05 May 2025

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarwns Global Services Private Vs Assessment Unit, National Faceless Limited, Mumbai Assessment Centre, New Delhi Pl-10/11, Gate No.4, Godrej- Boyce Complex, Pirojshanagar, L.B.S.Marg, Vikhroli (West), Mumbai-400 079 Pan: Aaacw2598L Appellant Respondent

For Appellant: ShriPorus Kaka A/w Manish KanthFor Respondent: Shri Pankaj Kumar (CIT DR)

Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 253

Global Services Pvt. Ltd., Singapore. For the impugned assessment year, the assessee filed its return of income, and the case was selected for complete scrutiny under the Computer Assisted Scrutiny Selection (CASS). The assessee, being an IT-enabled service provider, delivers a diverse portfolio of outsourcing solutions to clients globally

Sant Kirpal Vidyak Mission, Ludhiana vs. ITO (Exemption), Chandigarh

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

ITA 561/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh02 May 2025AY 2017-18

Bench: Sh. Laliet Kumar Hon'Ble & Sh. Krinwant Sahay, Hon'Ble(Physical Hearing)

Section 12ASection 143(3)Section 154Section 250

declaring NIL income belatedly and also filed audit report in form 10B on 31-08-2018 after due date. The case was selected for complete scrutiny. 3.2 It is observed by the AO that the appellant filed its ITR for the A.Y. 2017-18 on 17.3.2018 belatedly and audit report

Kolkata Craft Combine Society, Kolkata vs. ITO, Ward-50(3), Kolkata

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

ITA 882/KOL/2024[2017-18]Status: DisposedITAT Kolkata01 May 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 143(3)Section 250Section 69A

working with underprivileged community. The assessee had filed the return of income declaring loss of Rs. 4,18,323/-. The case was selected for complete scrutiny and a sum of Rs.39,42,500/- was added to the income on account of deposits in the bank account and the total income

Apurva Natvar Parikh & Co. Pvt Ltd, Mumbai vs. The Principle Commissioner of Income Tax, Mumbai-6, Mumbai

In the result, the appeal of the assessee is

ITA 2646/MUM/2024[2018-19]Status: DisposedITAT Mumbai01 May 2025AY 2018-19

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Madhur Agarwal, ARFor Respondent: Dr. K.R. Subhash, (CIT-DR)

Section 143(3)Section 14ASection 263

rival submission, have also perused the relevant records as also the Paper Book submitted by the ld.AR. Assessee's case was selected for 'Complete scrutiny' as per scrutiny guidelines of CBDT and the assessment was completed u/s 143(3) of the Acton 27.09.2021 accepting the returned income.It is noticed that ... sections 143(3A) & 143(3B) of the Income-tax Act Rs.0 07/04/2021 ITBA/AST/S/143(3)/2021-22/1032268687(1) ASSESSMENT ORDER 1. The case was selected for Complete Scrutiny assessment under the E-assessment Scheme, 2019 on the following issues:-- S. No. Issues i. Refund Claim ii. Contract Receipts or Fees Sales Turnover/Receipts

Income Tax Officer, Surat vs. Lalit Vanarsibhai Patel, Surat

In the result, the appeal of the revenue is dismissed

ITA 849/SRT/2024[2017-18]Status: DisposedITAT Surat30 Apr 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.849/Srt/2024 Assessment Year: (2017-18) (Physical Hearing) The Ito, Vs. Lalit Vanarsibhai Patel, Ward - 3(2)(9). 3/4, Navdurga Nagar Society, Surat Nr. Chowpati Main Road, Nana Varachha - 395006 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Celpp8445K (Appellant) (Respondent) Appellant By Shri Rasesh Shah, Ca Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 04/02/2025 Date Of Pronouncement 30/04/2025

Section 250Section 68Section 69A

dealer of TVS two-wheeler vehicles and had derived income from the said business during the year under consideration. The case was selected for complete scrutiny under CASS. Various notices were served upon the assessee. The Assessing Officer (in short, ‘AO’) also issued a show cause notice dated

Karuna Jain, Jaipur vs. ITO WD 2(1), Jpr, Jaipur

In the result, grounds raised by the assessee are dismissed

ITA 190/JPR/2025[2015-16]Status: DisposedITAT Jaipur30 Apr 2025AY 2015-16

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Appellant: Mr. Amit Kumar Jain, CA, Ld. ARFor Respondent: Mr. Anup Singh, Addl. CIT, Ld. DR

Section 10(38)Section 133ASection 139(4)Section 250Section 250(6)

declaring total income at Rs. 7,56,610/-. The case of the assessee was selected for complete scrutiny under CASS. It is observed that the assessee has claimed exempt long term capital gain of Rs. 66, 94,676/- on account of subscribing the IPO of M/s. HPC Bio Sciences

Vtp Foods, Pune vs. ITO Ward 7 (3), Pune

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

ITA 2878/PUN/2024[2017-18]Status: DisposedITAT Pune30 Apr 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Arvind Desai, Addl CIT DR

Section 143(2)

engaged in agricultural activities. It filed its return of income on 20.10.2017 declaring Nil income. The case was selected for complete scrutiny under the norms of CASS. Accordingly statutory notices u/s 143(2) and 142(1) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) were issued

Muktadevi Gramin Bigarsheti Sahakari Patsanstha Maryadit Gunjalwadi, Pune vs. ITO Ward 10(1), Pune

In the result, the appeal of the assessee is allowed

ITA 1842/PUN/2024[2020-21]Status: DisposedITAT Pune30 Apr 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.1841 & 1842/Pun/2024 निर्धारण वर्ष / Assessment Years : 2018-19 & 2020-21 Muktadevi Gramin Bigarsheti Sahakari Patsanstha Maryadit Gunjalwadi, At Post - Gunjalwadi, Taluka-Junnar, District - Pune 412401 Pan : Aaaam6151H अपीलार्थी / Appellant Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Ito, Ward-10(1), Pune Vs. प्रत्यर्थी / Respondent Shri Vilas R. Jadhav & Priyanka V. Jadhav Shri Ramnath P. Murkunde 04-02-2025 30-04-2025 आदेश / Order Per Astha Chandra, Jm : Two Appeals Filed By The Assessee Are Directed Against The Two Separate Order(S) Dated 02.07.2024 & 09.07.2024 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)"] Pertaining To Assessment Years (“Ays”) 2018-19 & 2020-21. For The Sake Of Convenience Both The Appeals Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Department byFor Respondent: Date of hearing

Section 143(2)Section 143(3)Section 56Section 57Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

respect of interest income received on its investments in the form of term deposits with banks. The case of the assessee was selected for complete scrutiny. Accordingly, statutory notice(s) u/s 143(2)/142(1) of the Act along with questionnaire were issued and served upon the assessee asking

Muktadevi Gramin Bigarsheti Sahakari Patsanstha Maryadit Gunjalwadi, Pune vs. ITO Ward10(1), Pune

In the result, the appeal of the assessee is allowed

ITA 1841/PUN/2024[2018-19]Status: DisposedITAT Pune30 Apr 2025AY 2018-19

For Appellant: Department byFor Respondent: Date of hearing

Section 143(2)Section 143(3)Section 56Section 57Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

Jcr Traders, Keelamathur vs. Deputy Commissioner of Income Tax Circle 1(1) Trichy, Trichy

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

ITA 333/CHNY/2025[2017-18]Status: DisposedITAT Chennai30 Apr 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.333/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Jcr Traders, Vs. The Deputy Commissioner Of 2/117, Thittakudi Road, Income Tax, Keelamathur, Tamil Nadu 621 173. Circle 1(1), Trichy. [Pan:Aalfj6942K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Ms. Deeptha, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 28.04.2025 घोषणा की तारीख /Date Of Pronouncement : 30.04.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 21.08.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2017-18. 2. We Find That This Appeal Is Filed With A Delay Of 93 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit

For Appellant: NoneFor Respondent: Ms. Deeptha, Addl. CIT

Section 142(1)Section 143(2)Section 144Section 40Section 69

firm and filed its return of income on 20.02.2018 declaring taxable income of ₹.11,25,800/-. The case has been selected for complete scrutiny under CASS and the Assessing Officer issued notice under section 143(2) of the Act dated 24.09.2018 and served on the assessee. As there

Muthu Dhanashekar, Mysuru vs. Income Tax Officer, Ward-1(1), Mysore

In the result, the appeal filed by the assessee is allowed for statistical purposes and the stay petition filed by the assessee is dismissed as infructuous

ITA 2444/BANG/2024[2017-18]Status: DisposedITAT Bangalore30 Apr 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Ankur Pai, CAFor Respondent: Shri Subramanian .S, JCIT-DR

Section 142(1)Section 68

assessee is a dealer in petroleum products and filed his return of income on 09/02/2018. Thereafter the case of the assessee was selected for complete scrutiny under CASS for the reason that large value of cash deposits were made during the demonetisation period. The AO issued Page

Sabirhusen Rasulbhai Malek, Surat vs. ITO, Ward 2(1), Bharuch

In the result, appeal of the assessee is dismissed

ITA 468/SRT/2024[2017-18]Status: DisposedITAT Surat29 Apr 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.468/Srt/2024 Assessment Year: (2017-18) (Hybrid Hearing) Sabirhusen Rasulbhai Malek Vs. The Ito, Indian Oil Pump, Devaliya Ward - 2(1), Narmada, Devaliya So - 391121 Bharuch "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aoppm9978Q (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Kinjal V. Shah, Ca Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 17/02/2025 Date Of Pronouncement 29/04/2025

Section 143(2)Section 250Section 270ASection 69A

electronically on 30.10.2017 for AY.2017-18, declaring total income of Rs.2,81,500/- and agricultural income of Rs.8,59,379/-. The case was selected for complete scrutiny under CASS. Various notices u/s 143(2) and 142(1) were issued and served upon the assessee for furnishing requisite details, information, clarification

Income Tax Officer, Ward- 2(3)(1), Surat vs. Hindustan Steel and Cement, Althan-Bhatar, Surat

Appeal of the revenue is partly allowed

ITA 266/SRT/2024[2017-18]Status: DisposedITAT Surat29 Apr 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.266/Srt/2024 Assessment Year: (2017-18) (Physical Hearing) The Ito, Vs. Hindustan Steel & Cement, Ward - 2(3)(1), Althan-Bhatar, Plot No. 1D, Sai Surat Ashish Society, Althan Bhatar, University Road, Surat - 394201 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaefh 5030 P (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Rasesh Shah, Ca Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 17/02/2025 Date Of Pronouncement 29/04/2025

Section 142(1)Section 250Section 68

case in brief are that assessee filed its return of income on 27.10.2018, declaring loss of Rs.3,52,076/-. The case was selected for complete scrutiny under CASS for the reason of “Abnormal increase cash deposits during the demonetization period as compared as pre-demonetization period”. Various notices were issued

New Chalai Agencies, Trivandrum vs. ACIT, Circle 1(2), Trivandrum

In the result the appeal filed by the assessee is allowed

ITA 807/COCH/2024[2017-18]Status: DisposedITAT Cochin29 Apr 2025AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Keshav Dubeyassessment Year : 2017-18 New Chalai Agencies Opposite Kairali Ford Inchakkal Acit Vallakadavu Po Vs. Circle-1(2) Kerala 695 008 Trivandrum Pan No :Aaffn7523C Appellant Respondent Appellant By : Shri N.S. Rajagopal, A.R. Respondent By : Smt. Leena Lal, Sr. D.R. Date Of Hearing : 30.01.2025 Date Of Pronouncement : 29.04.2025

For Appellant: Shri N.S. Rajagopal, A.RFor Respondent: Smt. Leena Lal, Sr. D.R

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

income for A.Y. 2017-18 was e-filed on 30/11/2017 declaring income at Rs. 1,13,65,030/-. Thereafter the case was selected for Complete Scrutiny under CASS. Accordingly, the Notice u/s. 143(2) of the Act was issued on 21/09/2018 and duly served upon the assessee electronically. Thereafter notices