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“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
42
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
39
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
35
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
21
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
20
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
13
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
11
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
11
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

Deohara Co-Operative Cane Development Union Limited, Bijnor vs. ITO, Ward-3(1), Bijnor

In the result, appeals of the assessee in Appeal Nos

ITA 2852/DEL/2024[2018-19]Status: DisposedITAT Delhi22 Apr 2025AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalita No.2851/Del/2024 (Assessment Year 2018-19) The Income Tax Seohara Co-Operative Cane Officer, Development Union Vs. Ward-3(1), Limited, 34-Station Road, Nazibabad-1, Up Seohara, Bijnor-246746. Pan-Aabas4970K (Appellant) (Respondent) Assessee By Shri Gurneet, Adv. Department By Shri Sahil Kumar Bansal, Sr. Dr Date Of Hearing 17/04/2025 Date Of Pronouncement 17/04/2025 O R D E R Per Bench: These Three Appeals Are Filed By The Assessee Against Three Separate Order Of The Ld. Commissioner Of Income Tax (Appeals) [Cit(A)], National Faceless Appeal Centre (Nfac) & All Are Dated 23.3.2024 For Ay 2018-19 Passed U/S 250 Of The Income Tax Act, 1961 (The Act). Seohara Co-Operative Cane Development Union India Vs. Ito 2. As All The Three Appeals Are Related To One Assessment Year Against Three Seperate Orders Passed U/S 144 R.W.S. 144B & Consequential Penalty Order U/S 270A & 271B Of The Act, Wherein The Ld. Cit(A) Has Dismissed The Appeals Filed By The Assessee On Account Of Delay In Filing The Respective Appeals. Since The Grounds Raised By The Assessee Relating To Dismissal Of Appeals Without Condoning The Delay In Filing, Thus All The Three Appeals Are Taken Together & Disposed Off By A Single Order.

Section 144Section 250Section 270ASection 271BSection 44A

that appellant is a co-operative society and filed its return of income on 30.03.2019 declaring NIL income. The assessment was taken up for complete scrutiny and the AO passed the order on 27.05.2021 u/s 144, on the basis of material available on record, wherein the income of the assessee

Seohara Co-Operative Cane Development Union Limited, Bijnor vs. ITO Ward 3(1), Bijnor

In the result, appeals of the assessee in Appeal Nos

ITA 2851/DEL/2024[2018-19]Status: DisposedITAT Delhi22 Apr 2025AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalita No.2851/Del/2024 (Assessment Year 2018-19) The Income Tax Seohara Co-Operative Cane Officer, Development Union Vs. Ward-3(1), Limited, 34-Station Road, Nazibabad-1, Up Seohara, Bijnor-246746. Pan-Aabas4970K (Appellant) (Respondent) Assessee By Shri Gurneet, Adv. Department By Shri Sahil Kumar Bansal, Sr. Dr Date Of Hearing 17/04/2025 Date Of Pronouncement 17/04/2025 O R D E R Per Bench: These Three Appeals Are Filed By The Assessee Against Three Separate Order Of The Ld. Commissioner Of Income Tax (Appeals) [Cit(A)], National Faceless Appeal Centre (Nfac) & All Are Dated 23.3.2024 For Ay 2018-19 Passed U/S 250 Of The Income Tax Act, 1961 (The Act). Seohara Co-Operative Cane Development Union India Vs. Ito 2. As All The Three Appeals Are Related To One Assessment Year Against Three Seperate Orders Passed U/S 144 R.W.S. 144B & Consequential Penalty Order U/S 270A & 271B Of The Act, Wherein The Ld. Cit(A) Has Dismissed The Appeals Filed By The Assessee On Account Of Delay In Filing The Respective Appeals. Since The Grounds Raised By The Assessee Relating To Dismissal Of Appeals Without Condoning The Delay In Filing, Thus All The Three Appeals Are Taken Together & Disposed Off By A Single Order.

Section 144Section 250Section 270ASection 271BSection 44A

that appellant is a co-operative society and filed its return of income on 30.03.2019 declaring NIL income. The assessment was taken up for complete scrutiny and the AO passed the order on 27.05.2021 u/s 144, on the basis of material available on record, wherein the income of the assessee

Seohara Co-Operative Cane Development Union Limited, Bijnor vs. ITO Ward 3(1), Bijnor

In the result, appeals of the assessee in Appeal Nos

ITA 2850/DEL/2024[2018-19]Status: DisposedITAT Delhi22 Apr 2025AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalita No.2851/Del/2024 (Assessment Year 2018-19) The Income Tax Seohara Co-Operative Cane Officer, Development Union Vs. Ward-3(1), Limited, 34-Station Road, Nazibabad-1, Up Seohara, Bijnor-246746. Pan-Aabas4970K (Appellant) (Respondent) Assessee By Shri Gurneet, Adv. Department By Shri Sahil Kumar Bansal, Sr. Dr Date Of Hearing 17/04/2025 Date Of Pronouncement 17/04/2025 O R D E R Per Bench: These Three Appeals Are Filed By The Assessee Against Three Separate Order Of The Ld. Commissioner Of Income Tax (Appeals) [Cit(A)], National Faceless Appeal Centre (Nfac) & All Are Dated 23.3.2024 For Ay 2018-19 Passed U/S 250 Of The Income Tax Act, 1961 (The Act). Seohara Co-Operative Cane Development Union India Vs. Ito 2. As All The Three Appeals Are Related To One Assessment Year Against Three Seperate Orders Passed U/S 144 R.W.S. 144B & Consequential Penalty Order U/S 270A & 271B Of The Act, Wherein The Ld. Cit(A) Has Dismissed The Appeals Filed By The Assessee On Account Of Delay In Filing The Respective Appeals. Since The Grounds Raised By The Assessee Relating To Dismissal Of Appeals Without Condoning The Delay In Filing, Thus All The Three Appeals Are Taken Together & Disposed Off By A Single Order.

Section 144Section 250Section 270ASection 271BSection 44A

that appellant is a co-operative society and filed its return of income on 30.03.2019 declaring NIL income. The assessment was taken up for complete scrutiny and the AO passed the order on 27.05.2021 u/s 144, on the basis of material available on record, wherein the income of the assessee

Singur Thana Lspa Co-Operative Marketing Society Ltd, Kolkata vs. ITO, Hooghly

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

ITA 970/KOL/2023[2018-19]Status: DisposedITAT Kolkata21 Apr 2025AY 2018-19

Bench: Shri Rajesh Kumarआयकर अपील सं/Ita No.968-970/Kol/2023 ("नधा"रण वष" / A.Yrs. : 2014-2015, 2017-2018 & 2018-2019) Singur Thana Lspa Vs Ito, Ward-23(2), Hooghly Cooperative Marketing Society Limited, C/O S.N.Ghosh&Associates,Advs 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kolkata-700001 Pan No. :Aabas0029 B (अपीलाथ" /Appellant) (""यथ" / Respondent) .. "नधा"रतीक"ओरसे /Assessee By : Shri Somnath Ghosh & Sarnath Ghosh, Advocates राज"वक"ओरसे /Revenue By : Ms. Madhumita Sas, Addl.Cit सुनवाई क" तार"ख / Date Of Hearing : 17/04/2025 घोषणा क" तार"ख/Date Of Pronouncement : 21/04/2025 आदेश / O R D E R These Are The Appeals Filed By The Assessee Against The Separate Orders All Dated 15.03.2023, Passed By The Ld. Cit(A), National Faceless Appeal Centre, (Nfac), Delhi For The Assessment Year 2014-2015, 2017- 2018 & 2018-2019. 2. As Per The Office Record, It Is Found That All The Three Appeals Of The Assessee Are Filed Belatedly By 120 Days Each. Looking To The Facts & Circumstances Of The Case, We Condone The Delay Of 120 Days Each In Fling All The Three Appeals & The Appeals Are Admitted For Adjudication.

For Appellant: Shri Somnath GhoshFor Respondent: Ms. Madhumita Sas, 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 8. The ld. AR submitted that the notice is not bearing to any of the above forms prescribed

Singur Thana Lspa Co-Operative Marketing Society Ltd, Kolkata vs. ITO, Hooghly

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

ITA 969/KOL/2023[2017-18]Status: DisposedITAT Kolkata21 Apr 2025AY 2017-18

Bench: Shri Rajesh Kumarआयकर अपील सं/Ita No.968-970/Kol/2023 ("नधा"रण वष" / A.Yrs. : 2014-2015, 2017-2018 & 2018-2019) Singur Thana Lspa Vs Ito, Ward-23(2), Hooghly Cooperative Marketing Society Limited, C/O S.N.Ghosh&Associates,Advs 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kolkata-700001 Pan No. :Aabas0029 B (अपीलाथ" /Appellant) (""यथ" / Respondent) .. "नधा"रतीक"ओरसे /Assessee By : Shri Somnath Ghosh & Sarnath Ghosh, Advocates राज"वक"ओरसे /Revenue By : Ms. Madhumita Sas, Addl.Cit सुनवाई क" तार"ख / Date Of Hearing : 17/04/2025 घोषणा क" तार"ख/Date Of Pronouncement : 21/04/2025 आदेश / O R D E R These Are The Appeals Filed By The Assessee Against The Separate Orders All Dated 15.03.2023, Passed By The Ld. Cit(A), National Faceless Appeal Centre, (Nfac), Delhi For The Assessment Year 2014-2015, 2017- 2018 & 2018-2019. 2. As Per The Office Record, It Is Found That All The Three Appeals Of The Assessee Are Filed Belatedly By 120 Days Each. Looking To The Facts & Circumstances Of The Case, We Condone The Delay Of 120 Days Each In Fling All The Three Appeals & The Appeals Are Admitted For Adjudication.

For Appellant: Shri Somnath GhoshFor Respondent: Ms. Madhumita Sas, 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 8. The ld. AR submitted that the notice is not bearing to any of the above forms prescribed

Singur Thana Lspa Co-Operative Marketing Society Ltd, Kolkata vs. ITO, Hooghly

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

ITA 968/KOL/2023[2014-15]Status: DisposedITAT Kolkata21 Apr 2025AY 2014-15

Bench: Shri Rajesh Kumarआयकर अपील सं/Ita No.968-970/Kol/2023 ("नधा"रण वष" / A.Yrs. : 2014-2015, 2017-2018 & 2018-2019) Singur Thana Lspa Vs Ito, Ward-23(2), Hooghly Cooperative Marketing Society Limited, C/O S.N.Ghosh&Associates,Advs 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kolkata-700001 Pan No. :Aabas0029 B (अपीलाथ" /Appellant) (""यथ" / Respondent) .. "नधा"रतीक"ओरसे /Assessee By : Shri Somnath Ghosh & Sarnath Ghosh, Advocates राज"वक"ओरसे /Revenue By : Ms. Madhumita Sas, Addl.Cit सुनवाई क" तार"ख / Date Of Hearing : 17/04/2025 घोषणा क" तार"ख/Date Of Pronouncement : 21/04/2025 आदेश / O R D E R These Are The Appeals Filed By The Assessee Against The Separate Orders All Dated 15.03.2023, Passed By The Ld. Cit(A), National Faceless Appeal Centre, (Nfac), Delhi For The Assessment Year 2014-2015, 2017- 2018 & 2018-2019. 2. As Per The Office Record, It Is Found That All The Three Appeals Of The Assessee Are Filed Belatedly By 120 Days Each. Looking To The Facts & Circumstances Of The Case, We Condone The Delay Of 120 Days Each In Fling All The Three Appeals & The Appeals Are Admitted For Adjudication.

For Appellant: Shri Somnath GhoshFor Respondent: Ms. Madhumita Sas, 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 8. The ld. AR submitted that the notice is not bearing to any of the above forms prescribed

Selvi, Trichy vs. Income Tax Officer, Ward 1(2), Trichy

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

ITA 119/CHNY/2025[2017-18]Status: DisposedITAT Chennai21 Apr 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 119/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Ms. Selvi, The Income Tax Officer, 30, North Street, Ward 1(2), Rockfort, Vs. Trichy. Trichy – 620 002. Pan: Aljps 2284C (""यथ"/Respondent) (अपीलाथ"/Appellant) अपीलाथ" क" ओर से/Appellant By : Shri P. Thangaraj, Advocate ""यथ" क" ओर से/Respondent By : Ms. Anitha, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 03.04.2025 घोषणा क" तारीख/Date Of Pronouncement : 21.04.2025 आदेश /O R D E R Per S.R. Raghunatha, Am: This Appeal Of The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi Dated 19.11.2024 For The Assessment Year 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal:- I. The Order Of The Learned Assessment Officer Is Against The Law, Weightage Of Evidence & All Probabilities Of The Case.

For Appellant: Shri P. Thangaraj, AdvocateFor Respondent: Ms. Anitha, Addl.CIT

return of income for the A.Y. 2017-18 ON 30.03.2018 admitting a total income of Rs.3,14,070/-. The case was selected for complete scrutiny under CASS for the reason that the cash deposit during the year and abnormal increase in cash deposited during demonetisation period as compared

Assistant Commissioner of Income Tax Ltu Circle 1, Nungambakkam Chennai vs. Sify Technologies Limited, Taramani Chennai

In the result, all the appeals filed by the Revenue are dismissed

ITA 2889/CHNY/2024[2012-13]Status: DisposedITAT Chennai17 Apr 2025AY 2012-13

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos. 1458, 1950 & 2889/Chny/2024 िनधा"रण वष"/Assessment Years: 2020-21, 2017-18 & 2012-13 The Deputy Commissioner Of Vs. M/S. Sify Technologies Limited, Income Tax/Acit, Ii Floor, Tidel Park No. 4, Ttt1 Large Taxpayer Unit Circle 1, Taramani S.O., Taramani, Chennai. Chennai 600 113. [Pan:Aaacs9032R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Shivanand K Kalakeri, Cit ""थ" की ओर से/Respondent By : Shri S.P. Chidambaram, Advocate सुनवाई की तारीख/ Date Of Hearing : 13.03.2025 घोषणा की तारीख /Date Of Pronouncement : 17.04.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Three Appeals Filed By The Revenue Are Directed Against Separate Orders Dated 19.02.2024, 07.08.2023 & 08.08.2023 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2020-21, 2017-18 & 2012-13. 2. Since Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed

For Appellant: Shri Shivanand K Kalakeri, CITFor Respondent: Shri S.P. Chidambaram, Advocate

return of income declaring income of ₹.98,53,74,050/- and the case of the 3 I.T.A. Nos.1458, 1950 & 2889/Chny/24 assessee was selected for complete scrutiny. After examining the details furnished by the assessee against statutory notices, the Assessing Officer noted that the assessee has shown an amount

Asst Commissioner of Income Tax Circle Ltu 1 Chennai, Nungambakkam vs. Sify Technologies Limited, Chennai

In the result, all the appeals filed by the Revenue are dismissed

ITA 1950/CHNY/2024[2017-18]Status: DisposedITAT Chennai17 Apr 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos. 1458, 1950 & 2889/Chny/2024 िनधा"रण वष"/Assessment Years: 2020-21, 2017-18 & 2012-13 The Deputy Commissioner Of Vs. M/S. Sify Technologies Limited, Income Tax/Acit, Ii Floor, Tidel Park No. 4, Ttt1 Large Taxpayer Unit Circle 1, Taramani S.O., Taramani, Chennai. Chennai 600 113. [Pan:Aaacs9032R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Shivanand K Kalakeri, Cit ""थ" की ओर से/Respondent By : Shri S.P. Chidambaram, Advocate सुनवाई की तारीख/ Date Of Hearing : 13.03.2025 घोषणा की तारीख /Date Of Pronouncement : 17.04.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Three Appeals Filed By The Revenue Are Directed Against Separate Orders Dated 19.02.2024, 07.08.2023 & 08.08.2023 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2020-21, 2017-18 & 2012-13. 2. Since Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed

For Appellant: Shri Shivanand K Kalakeri, CITFor Respondent: Shri S.P. Chidambaram, Advocate

return of income declaring income of ₹.98,53,74,050/- and the case of the 3 I.T.A. Nos.1458, 1950 & 2889/Chny/24 assessee was selected for complete scrutiny. After examining the details furnished by the assessee against statutory notices, the Assessing Officer noted that the assessee has shown an amount

Deputy Commissioner of Income Tax, Chennai vs. Sify Technologies Limited, Chennai

In the result, all the appeals filed by the Revenue are dismissed

ITA 1458/CHNY/2024[2020-21]Status: DisposedITAT Chennai17 Apr 2025AY 2020-21

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos. 1458, 1950 & 2889/Chny/2024 िनधा"रण वष"/Assessment Years: 2020-21, 2017-18 & 2012-13 The Deputy Commissioner Of Vs. M/S. Sify Technologies Limited, Income Tax/Acit, Ii Floor, Tidel Park No. 4, Ttt1 Large Taxpayer Unit Circle 1, Taramani S.O., Taramani, Chennai. Chennai 600 113. [Pan:Aaacs9032R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Shivanand K Kalakeri, Cit ""थ" की ओर से/Respondent By : Shri S.P. Chidambaram, Advocate सुनवाई की तारीख/ Date Of Hearing : 13.03.2025 घोषणा की तारीख /Date Of Pronouncement : 17.04.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Three Appeals Filed By The Revenue Are Directed Against Separate Orders Dated 19.02.2024, 07.08.2023 & 08.08.2023 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2020-21, 2017-18 & 2012-13. 2. Since Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed

For Appellant: Shri Shivanand K Kalakeri, CITFor Respondent: Shri S.P. Chidambaram, Advocate

return of income declaring income of ₹.98,53,74,050/- and the case of the 3 I.T.A. Nos.1458, 1950 & 2889/Chny/24 assessee was selected for complete scrutiny. After examining the details furnished by the assessee against statutory notices, the Assessing Officer noted that the assessee has shown an amount