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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

Deputy Commissioner of Income Tax, Central Circle-19, New Delhi, Delhi vs. Annai Infra Developers Limited, Tamil Nadu

In the result, the appeal filed by the Revenue is dismissed

ITA 3329/DEL/2023[2016-17]Status: DisposedITAT Delhi15 Apr 2025AY 2016-17

Bench: Shri Vikas Awasthy & Shri S.Rifaur Rahmandcit, Central Circle 19, Vs. Annai Infra Developers Limited, No.7, 4Th Floor, Sds Enclave, New Delhi. 2/5, Perundurai Road, Erode, Tamilnadu – 638 011. (Pan : Aahca5802A) Co No.2/Del/2024 (In Ita No.3329/Del/2023) (Assessment Year: 2016-17) Annai Infra Developers Limited, Vs. Dcit, Central Circle 19, No.7, 4Th Floor, Sds Enclave, New Delhi. 2/5, Perundurai Road, Erode, Tamilnadu – 638 011. (Pan : Aahca5802A) (Appellant) (Respondent) Assessee By : Shri Harshit Srivastav, Ca Revenue By : Shri Ashish Tripathi, Sr. Dr Date Of Hearing : 15.04.2025 Date Of Order : 15.04.2025 Order Per S. Rifaur Rahman: 1. The Revenue Has Filed Appeal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)-30, New Delhi [“Ld. Cit(A)”, For Short] Dated 13.09.2023 For The Assessment Year 2016-17 & The 2 Co No.2/Del/2024

For Appellant: Shri Harshit Srivastav, CAFor Respondent: Shri Ashish Tripathi, Sr. DR
Section 143Section 234B

construction of heavy infra projects, such as, irrigation projects, road projects, awarded by the Government Departments and private parties. The case was selected for complete scrutiny under CASS. Notices u/s 143 (2) and 142(1) of the Income-tax Act, 1961 (for short ‘the Act’) were issued and served

Inderpal Singh Chhabra, Rourkela vs. ACIT, Rourkela

In the result, appeal of the assessee is allowed

ITA 450/CTK/2024[AY 2018-19]Status: DisposedITAT Cuttack08 Apr 2025

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.450/Ctk/2024 (नििाारण वर्ा / Assessment Year : 2018-2019) Inderpal Singh Chhabra Vs Acit, Circle Rourkela Prop: Essar Enterprises Daily Market, C/O Crazy Cool, Main Rd, Po/Ps : Rourkela, Dist : Sundargarh Pan No. :Ajlpc 6337 J (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Shri P.K.Mishra & Shri Baidyanath Behera, Advocates राजस्व की ओर से /Revenue By : Shri Sanjay Kumar, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 08/04/2025 घोषणा की तारीख/Date Of Pronouncement : 08/04/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld Cit(A), Nfac, Delhi Dated 04.09.2024 In Din & Order No.Itba/Nfac/S/250/2024-25/1068345718(1)), For The Assessment Year 2018-19. 2. Shri P.K.Mishra, Advocate Appeared On Behalf Of The Assessee. Shri Sanjay Kumar, Ld Cit Dr Represented On Behalf Of The Revenue. 3. The Assessee Is Engaged In The Transportation Of Coal & Trading In Coals. It Was Submitted By Ld Ar That The Original Return Filed By The Assessee Came To Be Processed U/S.143(3) Of The Act By The Nfac & The Assessment Came To Be Completed On 10.02.2021 Accepting The Returned Income. Ld Ar Drew Our Attention To Page 3 Of The Paper Book

For Appellant: Shri P.K.Mishra & Shri BaidyanathFor Respondent: Shri Sanjay Kumar, CIT-DR
Section 142(1)Section 143(3)Section 206CSection 43B

copies of notice issued u/s.142(1) of the Act and annexures thereto, which reads as follows: 3 ANNEXURE Your case has been selected for Complete Scrutiny with the reason "Low Income from TCS receipts-Mining and quarrying". As per ITR, you have shown TCS amounting to Rs. 2004682/- and gross

Chiranjjeevi Wind Energy Ltd., Coimbatore vs. ACIT, Corporate Circle-1, Coimbatore

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

ITA 1857/CHNY/2024[2017-18]Status: DisposedITAT Chennai08 Apr 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1857/Chny/2024 िनधा"रण वष"/Assessment Year: 2017-18 Chiranjjeevi Wind Energy Limited, The Assistant Commissioner 26A, Kamaraj Road, Vs. Of Income Tax, Mahalingapuram, Corporate Circle -1, Pollachi, Coimbatore. Coimbatore – 642 002. Pan: Aaacc 8761H (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri R. Vijayaraghavan, 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 : 08.04.2025 आदेश /O R D E R Per S.R. Raghunatha: This Appeal Of The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi Dated 22.04.2024 For The Assessment Year 2017-18. 2. At The Outset, We Find That There Is A Delay Of 13 Days In Appeal Filed By The Assessee, For Which Petition For Condonation Of Delay Along With Reasons For Delay Has Been Filed. After Considering The Petition Filed By The Assessee & Also Hearing Both The Parties, We Find That There Is A Reasonable Cause For The Assessee In Not Filing Appeal On Or Before The Due Date Prescribed Under The Law & Thus, In The Interests Of Justice, We Condone Delay In Filing Of Appeal & Admit Appeal Filed By The Assessee For Adjudication.

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Ms. Anitha, Addl.CIT
Section 269SSection 271D

income for the assessment year 2017-18 on 26.10.2017 by declaring a loss of Rs.98,12,000/-. The assessee’s case was selected for ‘complete scrutiny’ under CASS and completed the scrutiny by passing an order u/s.143(3) of the Income Tax Act, 1961 (hereinafter