“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

P P Corporation, Rajkot vs. Principal Commissioner of Income Tax, Rajkot

In the result, the appeal of the assessee is allowed

ITA 245/RJT/2024[2018-19]Status: DisposedITAT Rajkot24 Apr 2025AY 2018-19

Section 133(6)Section 142(1)Section 143(3)Section 263

filed its return of income for assessment year (A.Y.) 2018-19, on 10/08/2018, declaring total income of Rs. Nil. The case was selected for complete scrutiny by "CASS". The Assessment was finalised u/s 143(3) r.w.s. 144B of the Income-tax Act, 1961, on 08/05/2021, accepting returned income

Pioneer Education Society, Haryana vs. ITO, Patna

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

ITA 405/PAT/2024[2016-17]Status: DisposedITAT Patna24 Apr 2025AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 405/Pat/2024 Assessment Year: 2016-2017 Pioneer Education Society,……….…….....……Appellant C-310/311, Unitech Business Zone Nirvana Country, South City-Ii, Sector-50, Haryana, Pin Code No.122018 [Pan:Aadap0174C] -Vs.- Income Tax Officer,……………………………….Respondent Ward-1(1), Patna, Lok Nayak Jai Prakash Bhawan, New Dak Bunglow, Patna-800001, Bihar Appearances By: Shri Yatin Sharma, Advocate, Appeared On Behalf Of The Assessee Rinku Singh, Cit (Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: April 21, 2025 Date Of Pronouncing The Order: April 24, 2025 O R D E R

Section 133(6)Section 142(1)Section 143(2)Section 271(1)(b)Section 68

running three schools, i.e. GEMS Public School in different places situated at Bhopal, Gwalior and Indore. The case of the assessee was selected for complete scrutiny through CASS for the reasons, i.e. (i) whether deduction claimed on account of business expenses is admissible or not and (ii) whether sundry creditors

Moti Ram Bairwa, Bassi, Jaipur vs. Income Tax Officer, Jaipur

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

ITA 1504/JPR/2024[2016-17]Status: DisposedITAT Jaipur24 Apr 2025AY 2016-17

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Appellant: Mr. Deevan Agarwal, CA, Ld. ARFor Respondent: Mrs. Swapnil Parihar, JCIT, Ld. DR

Section 139(4)Section 250Section 56(2)(vii)Section 69

return of income on 28.03.2017 u/s. 139(4) of the Act at Rs. 2,69,350/-. The case of the assessee was selected for complete scrutiny under CASS on the reason “Claim of Large Exempt Income”, as the assessee claimed exempt income amounting to Rs. 55 Lacs. After a detailed

Sardarsarovar Narmada Nigam Ltd., Gandhinagar vs. The Pr. CIT, Ahmedabad-3, Ahmedabad

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

ITA 821/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad24 Apr 2025AY 2018-19

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.821/Ahd/2024 िनधा"रण वष" /Assessment Year : 2018-19 Sardarsarovar Narmada The Pr.Cit, बनाम/ Nigam Ltd. Ahmedabad-3 V/S. Block-12, 1St Floor Ahmedabad – 380 014 Near Sachivalaya Complex Gandhiangar -382 010 (Gujarat) "थायी लेखा सं./Pan: Aaccs 6704 L अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Ms. Arti N. Shah, Ar Revenue By : Shri Alpesh Parmar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 22/04/2025 घोषणा की तारीख /Date Of Pronouncement: 24/04/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Ms. Arti N. Shah, ARFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 143(3)Section 144BSection 263Section 37(1)

revised return of income on 12.02.2019 declaring an enhanced loss of Rs.36,89,61,55,368/-. The case was selected for scrutiny under the Complete Scrutiny category through Computer Aided Scrutiny Selection (CASS) mechanism. Pursuant to the notices issued under sections ... constitute a lapse in the conduct of the assessment proceedings. It is particularly significant to note that the assessee’s case was selected for Complete Scrutiny under the Computer Aided Scrutiny Selection (CASS) Sardarsarovar Narmada Nigam Ltd. vs. The Pr.CIT Asst. Year : 2018-19 mechanism. In cases selected for Complete

Usmanbhai Hajibhai Ghanchi, Ahmedabad vs. The ITO, Ward-6(1)(1), Ahmedabad

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

ITA 34/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad24 Apr 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Tej Shah, A.RFor Respondent: Smt. Trupti Patel, Sr. D.R

Section 133(6)Section 144Section 147Section 68

income for assessment year 2017-18 on 27-03-2018 declaring total income of Rs. 18,62,134/-. The case was selected for complete scrutiny under CASS. In the course of the assessment, no compliance was made by the assessee. The Assessing Officer had made addition

Usmanbhai Hajibhai Ghanchi, Ahmedabad vs. The ITO, Ward-6(1)(1), Ahmedabad

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

ITA 915/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad24 Apr 2025AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Tej Shah, A.RFor Respondent: Smt. Trupti Patel, Sr. D.R

Section 133(6)Section 144Section 147Section 68

Ramakrishna Teletronics Private Limited, Hyderabad vs. ITO., Ward-3(2), Hyderabad

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

ITA 988/HYD/2024[2017-18]Status: DisposedITAT Hyderabad24 Apr 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA P Murali Mohan RaoFor Respondent: MS. U. Mini Chandran, CIT-DR

Section 115JSection 250Section 69A

Rs.14,46,191/- for the impugned assessment year 2017- 2018. 5.1. The case of the appellant-company has been selected for 'complete scrutiny' under CASS and various notices u/sec.143(2)/142(1) of the Act were issued and served on the appellant-company. Since, the assessee failed to respond

Kamineni Health Services Private Limited, Hyderabad vs. ACIT, Circle - 2(1), Hyderabad

In the result, appeal of the Assessee is partly allowed

ITA 406/HYD/2023[2016-17]Status: DisposedITAT Hyderabad24 Apr 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri Sashank Dundu, AdvocateFor Respondent: Shri Srinath Sadanala, Sr. AR

Section 142(1)Section 143(1)Section 143(2)Section 36(1)(iii)

income of Rs.(-)64,54,988/- for the impugned assessment year 2016-17. The return was processed u/s.143(1). The case was selected for complete scrutiny under Manual Selection and notice u/s 143(2) of the Act dated 08.09.2017 was issued and served on assessee. Subsequent notices u/s.142(1) were

M/S. Shanti Vyapar Pvt. Ltd., Kolkata vs. ITO, Ward 9(1), Kolkata

ITA 299/KOL/2025[2014-15]Status: DisposedITAT Kolkata24 Apr 2025AY 2014-15

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri Saumitra Choudhury, ARFor Respondent: Shri Sailen Samadder, DR

Section 142(1)Section 143(2)Section 143(3)Section 56(2)

given a very comprehensive questionnaire calling upon the assessee to respond and reply the same as if it were a complete scrutiny. The Id. AR submitted that if at all the Id. AO on the basis of examination of evidences and details before him was of the opinion that ... examination then he was required record satisfaction/opinion for the same and follow the procedure laid down under the Act to convert limited scrutiny into complete scrutiny and only then the assessment order could be framed accordingly failing which the assessment framed

Kazi Zainal Absar, Asansol vs. ITO, Ward-1(1), Asansol

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

ITA 348/KOL/2024[2017-18]Status: DisposedITAT Kolkata24 Apr 2025AY 2017-18

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 194Section 250Section 40

Machineries. The assessee had e-filed his return of income showing total income of Rs. 6,26,730/-. The case was taken up for complete scrutiny through CASS and additions for non-deduction of TDS on interest payment, repair and maintenance charges, machine hire charges and addition

Basudeb Das, South 24 Parganas vs. I.T.O., Ward - 26(1), Kolkata

In the result, appeal of the assessee is allowed

ITA 1308/KOL/2024[2017-2018]Status: DisposedITAT Kolkata24 Apr 2025AY 2017-2018

Bench: Shri Rajesh Kumarआयकर अपील सं/Ita No.1308/Kol/2024 (नििाारण वर्ा / Assessment Years : 2017-2018) Basudeb Das, Vs Ito, Ward-26(1), Kolkata Mamudpur, Charashyamdas, Bishnupur, South 24 Parganas West Bengal Pan No. :Aqppd9974P (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररतीकीओरसे /Assessee By : Shri Soumitra Choudhury, Advocate राजस्वकीओरसे /Revenue By : Ms. Madhumita Das, Addl.Cit सुनवाई की तारीख / Date Of Hearing : 17/04/2025 घोषणा की तारीख/Date Of Pronouncement : 24/04/2025 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Order Dated 09.03.2024, Passed By The Ld. Cit(A), National Faceless Appeal Centre, (Nfac), Delhi For The Assessment Year 2017-2018. 2. As Per The Appeal Record, It Is Observed That The Appeal Is Filed Belatedly By 34 Days. In This Regard, The Assessee Has Filed Condonation Application Stating Therein Sufficient Reasons For Condonation Of Delay. Considering The Reasons Stated In The Application Of The Assessee, The Delay Of 34 Days In Filing The Present Appeal Is Condoned & The Appeals Is Admitted For Hearing. 3. At The Time Of Hearing, Ld. Counsel Of The Assessee Has Raised The Additional Ground Which Is Extracted As Under :- 1. For That On The Facts Of The Case, The Assessing Officer Issuing The Notice U/S. 143(2) Of The I.T. Act, 1961 On 24.09.2018 Did Not Have Jurisdiction Over The Case Of The Assessee, As There Was No Mention Of The Type Of Scrutiny Under Which The Case Of The Assessee Has Been Selected, Hence The Notice Is Bad-In-Law

For Appellant: Shri Soumitra Choudhury, AdvocateFor Respondent: Ms. Madhumita Das, Addl.CIT

Section 143(2)Section 143(3)

notice u/s.143(2) of the Act to be issued in any of the three following forms :- ❖ Limited Scrutiny (Computer Aided Scrutiny Selection ❖ Complete Scrutiny (Computer Aided Scrutiny Selection) ❖ Compulsory Manual Scrutiny 6. The ld. AR submitted that the notice is not bearing to any of the above forms prescribed

Jatinder Singh (HUF), Kalbadevi vs. Income Tax Officer, Mumbai

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

ITA 1779/MUM/2025[2017-18]Status: DisposedITAT Mumbai24 Apr 2025AY 2017-18

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeejatinder Singh (Huf) Vs Income-Tax Officer 413-F, Vasantwadi, Kalbadevi Ward 23(1)(5), Mumbai. Room No.114, 1St Floor, Matru Road, Kalbadevi, Mumbai-400 002 Mandir, Tardeo Road, Mumbai-400 Pan: Aaehj8442H 007 Appellant Respondent

For Appellant: NoneFor Respondent: Shri Asif Karmali (Sr.DR)

Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 250Section 68

record. The assessee filed the return of income under section 139(1) declaring total income at Rs.29,75,705/-. The case was selected for complete scrutiny under CASS and notice under section 143(2) of the Act was served on the assessee. The assessee is a manufacturer and trader

Ranee Narah, Guwahati vs. Assistant Commissioner of Income Tax, Circle-3, Guwahati

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

ITA 84/GTY/2020[2016-17]Status: DisposedITAT Guwahati23 Apr 2025AY 2016-17

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 143(3)Section 234ASection 234BSection 234CSection 250Section 68Section 69

erroneous on points of law. 2. For that the learned Assessing Officer is not justified in converting the limited scrutiny case into complete scrutiny case without any approval of higher authority as per provision of the Act and Learned CIT Appeals also erred in confirming the same in the facts

Gujarat Vepari Mahamandal Sahkari Audyogik Vasahat Limited, Ahmedabad vs. The ITO, Ward-3(3)(5), Ahmedabad

The appeal of the assessee is partly allowed for statistical purpose

ITA 288/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad23 Apr 2025AY 2022-23

Bench: Ms. Suchitra Kamble

For Appellant: Shri M. S. Chhajed, A.RFor Respondent: Shri S. K. Agal, Sr. DR

Section 143(1)Section 143(2)Section 143(3)Section 144BSection 80Section 80PSection 80P(2)(d)

declaring total income at Nil under the Income Tax Act, 1961. The case of the assessee was selected for complete scrutiny under CASS for the reason “claim of deduction u/s 80P by entities that have received large amount of interest from a banking company” and required statutory notices

Antpara Samabay Krishi Unayan Samity Limited, Antpara, Burdwan vs. ACIT, NFAC, Delhi/ ITO, Ward - 1(1), Burdwan

In the result, all the captioned appeals of the assessee are allowed

ITA 2053/KOL/2024[2020-2021]Status: DisposedITAT Kolkata23 Apr 2025AY 2020-2021

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma

Section 143(2)Section 250Section 80PSection 80P(2)(a)

specific issue relating to overdue interest provisions was never raised for an issue in scrutiny and the Assessing Officer without converting limited scrutiny to complete scrutiny cannot go beyond the scope of limited scrutiny. Therefore, the addition made by the Assessing Officer on this issue

Antpara Samabay Krishi Unayan Samity Limited, Antpara vs. ACIT, NFAC, Delhi

In the result, all the captioned appeals of the assessee are allowed

ITA 1635/KOL/2024[2018-19]Status: DisposedITAT Kolkata23 Apr 2025AY 2018-19

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma

Section 143(2)Section 250Section 80PSection 80P(2)(a)

Antpara Samabay Krishi Unnayan Samity Limited, Antpara vs. I.T.O., Ward 1(1), Burdwan, Aaykar Bhawan

In the result, all the captioned appeals of the assessee are allowed

ITA 1634/KOL/2024[2017-18]Status: DisposedITAT Kolkata23 Apr 2025AY 2017-18

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma

Section 143(2)Section 250Section 80PSection 80P(2)(a)

Antpara Samabay Krishi Unnayan Samity Limited, Antpara vs. ITO Ward 1(1), Burdwan

In the result, all the captioned appeals of the assessee are allowed

ITA 1632/KOL/2024[2013-14]Status: DisposedITAT Kolkata23 Apr 2025AY 2013-14

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma

Section 143(2)Section 250Section 80PSection 80P(2)(a)

Mmtc Ltd vs. DCIT Circle 5(1)

In the result the appeal of the assessee is allowed

ITA 2732/DEL/2006[2004-2005]Status: DisposedITAT Delhi23 Apr 2025AY 2004-2005

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.Clix Capital Services Pvt. Ltd, Vs. Pcit, Plot No. 23, 5Th Floor, Aggarwal Delhi-1, Delhi Corporate Tower Govind Lal Sikka Marg, Rajendra Place, West Delhi, New Delhi, Delhi, India, 110008 (Appellant) (Respondent) Pan: Aaacc0642F

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Sanjay Kumar Bharati, CIT DR

Section 139(1)Section 143(3)Section 144BSection 263Section 37

filed revised return on 29.03.2019 declaring loss of Rs. 10,68,63,896/-. The case of the assessee was selected for complete scrutiny to examine the following issues:- i. Claim of Any Other Amount Allowable as Deduction in Schedule BP ii. Depreciation Claim iii. Investments/Advances/Loans iv. Refund Claim v. Business

B.P. Oil Mills Ltd., Agra vs. Pr.CIT-1, Agra

The appeal stand allowed in terms of our above order

ITA 25/AGR/2021[2015-16]Status: DisposedITAT Agra22 Apr 2025AY 2015-16

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Sh. Deependra Mohan, CA – Ld. ARFor Respondent: Sh. Sukesh Kumar Jain – Ld. CIT/DR

Section 133(6)Section 142(1)Section 143(3)Section 263

Accordingly, the assessee was show-caused. The assessee refuted all these allegations and stated that the case was subjected to complete scrutiny and detailed replies were submitted by the assessee form time to time. The assessee also demonstrated that closing stock-in-trade was much higher than as computed ... these issues. Aggrieved, the assessee is in further appeal before us. 4. It could be observed that the assessee’s case was subjected to complete scrutiny. During the course of assessment proceedings, various queries were raised by Ld. AO calling for financial statement, tax audit report and various other documents