“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

Indiabulls Commercial Credit Limited, New Delhi vs. PCIT (Central), Mumbai-3, Mumbai

In the result, the appeal is dismissed

ITA 2844/MUM/2024[2019-20]Status: DisposedITAT Mumbai24 Mar 2025AY 2019-20

For Appellant: Respondent byFor Respondent: Date of Hearing

Section 143(3)Section 263Section 94(7)

which was later revised on 26.11.2020 declaring total income Rs.3,28,38,66,670/-Subsequently, assessee's case was selected for 'Complete scrutiny' as per scrutiny guideline of CBDT and the assessment was completed u/s 143(3) of the Act on 27.09.2021 accepting the returned income. 3.1 The ld.PCIT ... have been pointed out by the ld.PCIT as also issues as stated by him on the front page of the order, being part of complete scrutiny which he was supposed to do. A scanned copy of the assessment order is annexed here below which speaks for itself:- Page

Jagjeet Singh & Sons, Guwahati vs. ACIT Cir-2, Guwahati

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

ITA 216/GTY/2024[2017-18]Status: DisposedITAT Guwahati21 Mar 2025AY 2017-18

Bench: Shri Manomohan Das, Hon’Ble & Shri Rakesh Mishra, Hon’Ble

For Appellant: Adj. PetitionFor Respondent: Shri Kaushik Ray, DCIT

Section 142(1)Section 143(2)Section 144Section 250Section 68

assessee e-filed his Return of Income on 06.11.2017 showing total income of Rs. 1,14,92,020/-. The case was selected for complete scrutiny through CASS and notice u/s 143(2) of the Act was issued on 10.08.2018 which was not responded by the assessee. Notice

Ashokkumar Projects India Pvt. Ltd., Porbandar vs. The Pr. CIT, Jamnagar

In the result, appear of the assessee is allowed

ITA 83/RJT/2024[2018-19]Status: DisposedITAT Rajkot21 Mar 2025AY 2018-19

Bench: Dr.Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.83/Rjt/2024 (िनधा"रणवष" / Assessment Year: (2018-19) (Physical Hearing) Ashokkumar Projects India P. Vs. The Pr. Commissioner Of Ltd. Income Tax, 4Th Floor, Manek Centre, P.N. Cholera Arcade, M.G. Road Opposite, Bhaveshwar Mahadev Marg, Jamnagar - 361008 Temple, Porbandar – 360575 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aamca5891Q (Assessee) (Respondent)

For Appellant: Shri Dushyant Maharshi, ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)

Section 142(1)Section 143(3)Section 192Section 194CSection 263Section 40

income for assessment year (AY) 2018-19, on 27/02/2019, declaring total income of Rs.28,36,344/-. The assessee`s case was selected for complete scrutiny, through CASS and assessment was finalized u/s143(3) of the Income-tax Act, 1961, vide order dated 03/06/2021, by determining total income at Rs.28

Assistant Commissioner of Income Tax, Circle-3, Bsnl Rttc Building vs. The Wardha District Central Cooperative Bank Ltd, Wardha

In the result, Revenue’s appeal stands allowed for statistical purposes

ITA 99/NAG/2024[2017-18]Status: DisposedITAT Nagpur21 Mar 2025AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Abhay Y. Marathe

income at (loss) Rs. 19,33,28,507/-. This return was processed by CPC as such. The case was picked up by CASS for complete scrutiny for the main reasons "closing stock, disallowance for payment of gratuity, deduction and deposit of TDS, investments /advances/loans, expenses incurred for earning exempt income

M/S Ashwinkumar Kailashchand Bajoriya, Akola vs. ITO Ward-1, Akola

In the result, appeal by the assessee stands dismissed

ITA 374/NAG/2024[2016-17]Status: DisposedITAT Nagpur21 Mar 2025AY 2016-17

Bench: Shri V. Durga Rao

For Appellant: Shri R.K. GaneriwalFor Respondent: Shri Abhay Y. Marathe

Section 41Section 41(1)

Bajoriya Tractor. On 04/04/2017, the assessee filed its return of income disclosing total income at ` 1,81,490. The case was selected for complete scrutiny through CASS. Accordingly, statutory notices were issued to the assessee through ITBA portal. The Assessing Officer called for the details / documents and evidences such

Vinay Ramsharandas Agrawal, Nagpur vs. Principal Commissioner of Income Tax-II, Nagpur

In the result, appeal by the assessee stands allowed

ITA 110/NAG/2023[2017-18]Status: DisposedITAT Nagpur21 Mar 2025AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kishore P. DewaniFor Respondent: Shri Sandipkumar Salunke

Section 143(3)Section 263

order. The learned Departmental Representative further submitted written submissions which are as under:– “Merits of the Case: i. The present case was selected for complete scrutiny through Cass for verification of various issues including the capital gain/loss on sale of property. Thus, it was imperative for the Assessing Officer

Infosoft Global P Ltd., Kolkata vs. DCIT, Cir. 1(1), Kolkata

In the result, the appeal of the assessee is dismissed

ITA 501/KOL/2024[2020-21]Status: DisposedITAT Kolkata21 Mar 2025AY 2020-21

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(1)Section 143(3)Section 250

processed u/s 143(1) of the Act and income was assessed at Rs. 36,05,13,647/-. Thereafter, the case was selected for complete scrutiny under CASS and the assessment was completed on 22/09/2022, wherein the AO disallowed an amount of Rs. 2,07,954/- as 'Equalization levy written

Income Tax Officer Ward 21(1), Delhi, C.R. Building, I.P. Estate vs. Rampur Engineering Company Ltd, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 3085/DEL/2024[2015-16]Status: DisposedITAT Delhi21 Mar 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shukla[Assessment Year: 2015-16]

For Appellant: Shri Sumit Lal chandani, AdvocateFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 143(2)Section 68

return of income on 30.09.2015 declaring an income ofRs. NIL and claiming a loss of Rs. 26,52,667/-. Further, the case wasselected for complete scrutiny. Accordingly notice u/s 143(2) of the IT Act,1961 dated 21.03.2016 was issued to the assessee and duly served upon. In compliance

Harkiran Commar, New Delhi vs. Pr. CIT-10, Delhi

In the result, appeal of the assessee is allowed

ITA 1428/DEL/2023[2018-19]Status: DisposedITAT Delhi21 Mar 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalpr. Commissioner Of Mrs. Harkiran Commar Income Tax-10, 28, Poorvi Marg, Vs. New Delhi Vasant Vihar, New Delhi-110057 Pan: Aagpc2911C (Appellant) (Respondent) Assessee By Sh. Sanjiv Chaudhary, Ca Sh. Anil Chopra, Ca & Sh. Praveen Kumar, Ca Department By Sh. Surender Pal, Cit-Dr Date Of Hearing 24/02/2025 Date Of Pronouncement 21/03/2025 O R D E R

Section 143(3)Section 263Section 263(1)Section 50CSection 54Section 54F

requires further investigation. In that case, the AO should take necessary approval from the higher authorities to convert the assessment from limited scrutiny to complete scrutiny and then can examine such other issues. Since, in the instant case, no such procedure was followed nor such satisfaction was recorded, therefore

Knauf India Pvt Ltd (Earlier Know As Usg Boral Building Products (India) Pvt Ltd), Gurgaon vs. ITO, Ward-14(3), New Delhi

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

ITA 2061/DEL/2022[2018-19]Status: DisposedITAT Delhi21 Mar 2025AY 2018-19

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajit Kumar Jain, CAFor Respondent: Shri S.K. Jhadav, CIT DR

Section 144Section 37Section 92CSection 92C(3)Section 92D

brought forward loss and Rs.(-) 14,88,27,460/- as deemed income u/s 115JB of the Act. The case was selected for complete scrutiny. Accordingly, notices u/s 143(2) and 142(1) were issued and served on the assessee. The assessee has declared international transactions in its annual report

Knauf India Pvt Ltd (Earlier Know As Usg Boral Building Products (India) Pvt Ltd), Haryana vs. ITO, Ward 14 (3), New Delhi

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

ITA 2060/DEL/2022[2017-18]Status: DisposedITAT Delhi21 Mar 2025AY 2017-18

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajit Kumar Jain, CAFor Respondent: Shri S.K. Jhadav, CIT DR

Section 144Section 37Section 92CSection 92C(3)Section 92D

Airona Tiles Limited, Sabarkantha vs. The DCIT, Circle Himatnagar Presently the DCIT, Circle-2(1)(1), Ahmedabad

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

ITA 1127/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad20 Mar 2025AY 2016-17

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.1127/Ahd/2023 िनधा"रण वष" /Assessment Year : 2016-17 Airona Tiles Limited The Dcit बनाम/ Ceramic City Circle Himatnagar. V/S. At & Post : Dalpur Presently The Dcit, Kathwada Road Circle-2(1)(1) Sabarkantha – 383 120 (Gujarat) "थायी लेखा सं./Pan: Aanca 3712 D (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Anil N. Shah & Aatish Shah Ars Revenue By : Shri Purshottam Kumar, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 19 /03/2025 घोषणा की तारीख /Date Of Pronouncement: 20 /03/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: This Appeal Has Been Preferred By The Assessee Against The Order Dated 13.10.2022 Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”], Arising Out Of The Assessment Order Dated 21.12.2018 Passed Under Section 143(3) Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act”] By Dcit/Acit, Circle Himatnagar [Hereinafter Referred To As “Ao”] For The Assessment Year (Ay) 2016-17. Airona Tiles Ltd. Vs. The Dcit, Circle Himatnagar - Presently The Dcit, Circle-2(1)(1) Asst. Year : 2016-17

For Appellant: Shri Anil N. Shah &For Respondent: Shri Purshottam Kumar, Sr.DR

Section 143(1)Section 143(2)Section 143(3)Section 36(1)(va)Section 40A(3)Section 43BSection 68

total income of Rs.62,63,380/-. The return was processed under Section 143(1) of the Act. Subsequently, the case was selected for complete scrutiny, and notices under Section 143(2) and 142(1) of the Act were issued and duly served. During the course of the assessment proceedings

Parshavnath Associates, Kota vs. ACIT/DCIT, Central Circle, Kota

In the result, both the appeal filed by separate assessee are allowed in terms of the above observations

ITA 1358/JPR/2024[2018-19]Status: DisposedITAT Jaipur19 Mar 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Mahendra Gargieya, Adv.&For Respondent: Smt. Runi Pal, CIT a

Section 133ASection 139Section 143(3)Section 234ASection 244ASection 69C

income of Rs.4,77,29,130/- which also included such additional income of Rs. 2,00,10, 200/-.Thereafter, the case was selected for Complete Scrutiny assessment and the impugned assessment was completed vide order dated 27/04/2021 passed u/s 143(3). 2. The AO completed the assessmentu/s

Parshwanath Buildestate Private Limited, Kota vs. ACIT/DCIT, Central Circle, Kota

In the result, both the appeal filed by separate assessee are allowed in terms of the above observations

ITA 1357/JPR/2024[2018-19]Status: DisposedITAT Jaipur19 Mar 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Mahendra Gargieya, Adv.&For Respondent: Smt. Runi Pal, CIT a

Section 133ASection 139Section 143(3)Section 234ASection 244ASection 69C

Abil Realty Pvt. Ltd., Pune vs. ITO, Ward 1(1), Pune

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

ITA 446/PUN/2024[2016-17]Status: DisposedITAT Pune19 Mar 2025AY 2016-17

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17 Abil Realty Pvt. Ltd. Ito, Ward 1(1), Pune Abil House, 2 Ganesh Khind Road, Vs. Range Hill Corner, Pune – 411007 Pan: Aaica8531I (Appellant) (Respondent) Assessee By : Shri Sanket M Joshi & Mandar Joshi Department By : Shri Amol Khairnar Cit-Dr Date Of Hearing : 08-01-2025 Date Of Pronouncement : 19-03-2025 O R D E R

For Appellant: Shri Sanket M Joshi & Mandar JoshiFor Respondent: Shri Amol Khairnar CIT-DR

Section 143(1)Section 143(2)Section 2(22)(e)

said addition u/s 2(22)(e) made by the A.O. without obtaining requisite approval for conversion of the case from limited scrutiny to complete scrutiny, was unsustainable in law. 8. However, the Ld. Counsel for the assessee did not press the additional ground No.1 for which ... confine the scrutiny assessment proceedings to the issues under limited scrutiny and in case he wants to expand the scope of the same for complete scrutiny or issues other than the issues that have been the criteria as per the limited scrutiny, he has to take permission from the PCCIT

R Vidyasagar Rao, Hyderabad vs. DCIT., Circle-3(1), Hyderabad

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

ITA 1404/HYD/2024[2020-21]Status: DisposedITAT Hyderabad19 Mar 2025AY 2020-21

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA T Rajendra Prasad And Shri P. Rosi Reddy, AdvocateFor Respondent: Dr. Sachin Kumar, Sr AR

Section 142(1)Section 143(2)Section 32

income on 17.12.2020 declaring total income of Rs.10,20,62,080/-. The case of the assessee has 2 ITA.No.1404/Hyd./2024 been selected for complete scrutiny and during the course of assessment proceedings, the Assessing Officer issued notices u/sec.143(2) and 142(1) of the Income

ITO, Ward-3(1), Gaya vs. Shri Gauri Textiles Industries, Gaya

In the result, the appeal filed by the revenue is dismissed and corresponding cross-objection filed by the assessee is allowed

ITA 118/PAT/2020[2017-18]Status: DisposedITAT Patna18 Mar 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.118/Pat/2020 Assessment Year: 2017-18 Ito, Ward-3(1), Gaya…………….………………………………….…..……Appellant Vs. Shri Gauri Textile Industries, Gaya…………...........……........……...…..…..Respondent Buniadgaj Manpur, Gaya, Bihar-823003. [Pan: Aalfs4803J] C.O. No.5/Pat/2021 (Arising Out Of I.T.A. No.118/Pat/2020) Assessment Year: 2017-18 Shri Gauri Textile Industries, Gaya ……………….………………..….…..Cross-Objector Buniadgaj Manpur, Gaya, Bihar-823003. [Pan: Aalfs4803J] Vs. Ito, Ward-3(1), Gaya………….................................……........……....…..…..Respondent Appearances By: Shri Manish Rastogi, Advocate, Appeared On Behalf Of The Assessee. Shri Ashok Kumar, Cit, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : January 30, 2025 Date Of Pronouncing The Order : March 18, 2025 Order Per Sonjoy Sarma: The Revenue Has Filed An Appeal Against The Order Dated 31.08.2020 By The Commissioner Of Income Tax (Appeals)-1, Patna [Hereinafter Referred To As The ‘Cit(A)’] & The Assessee Has Filed The Corresponding Cross-Objection Relating To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That A Survey Was Conducted On 07.02.2017 In The Case Of The Assessee, A Partnership Firm Engaged In Trading Business Of Cotton Yarn & Hosiery Yarn. During The Survey, It Was Observed That The Assessee Has Made Substantial Deposits In Various Bank Accounts Linked With The Firm. However, The Assessee Disclosed

Section 143(2)

filed return of income for the assessment year 2017-18 by declaring total income of Rs.13,78,254/-. The case was subsequently selected for complete scrutiny and notices u/s 143(2) and 142(1) of the Act were issued. In response to the notices, the assessee submitted various details

Shrishti Technologies, Baddi vs. Income Tax Officer, Parwanoo

In the result, appeal of the assessee is allowed

ITA 96/CHANDI/2024[2018-2019]Status: DisposedITAT Chandigarh18 Mar 2025AY 2018-2019

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

For Appellant: Shri Manoj Kumar,CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT Sr.DR

Section 194Section 194lSection 250Section 271C

detail on the record. The relevant part of the assessment order reads as under : ASSESSMENT ORDER 1. The case was selected for complete scrutiny assessment under the E- assessment Scheme,2019 on the following issues :- 2. On the basis of material available on record, the explanation filed by the assessee

Sanjay Mohanlal Bafna, Pune vs. ACIT, Circle 5, Pune

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

ITA 2047/PUN/2024[2018-19]Status: DisposedITAT Pune18 Mar 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Sanjay Mohanlal Bafna Acit, Circle 5, Pune A 33, Sagar Bunglow, Vs. Vidyasagar Colony, Market Yard, Pune - 411037 Pan: Abtpb8135H (Appellant) (Respondent) Assessee By : Shri Nikhil Pathak Department By : Shri Ajay Kumar Keshari – Cit Date Of Hearing : 28-01-2025 Date Of Pronouncement : 18-03-2025 O R D E R

For Appellant: Shri Nikhil PathakFor Respondent: Shri Ajay Kumar Keshari – CIT

Section 143(2)Section 80I

after claiming deduction under chapter VI-A of the Income Tax Act, 1961 (hereinafter referred to as „the Act‟). The case was selected for complete scrutiny assessment under the E- assessment Scheme, 2019 on the following issues: 2 S. No. Issues i. Refund Claim ii. Deduction claimed for Industrial Undertaking

Late Smt. Priti A. Gandhi L/R. Shri Anilbhai A. Gandhi, Rajkot vs. The Pr. CIT-1, Rajkot

ITA 57/RJT/2021[2015-16]Status: DisposedITAT Rajkot17 Mar 2025AY 2015-16

Section 10(38)Section 143(3)Section 24Section 244ASection 263Section 68

24/09/2015, declaring total income of Rs.1,91,140/- and exempt income ofRs.1,32,63,709/-. The assessee`s case was selected for complete scrutiny with a reason to verify suspicious sale transaction in shares. The Assessment was completed u/s 143(3) of the Income-tax Act, on 26/12/2017, accepting