“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

Miss Pari Anil Gandhi, Rajkot vs. The Pr. CIT-1, Rajkot

ITA 51/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

Suchita Bhatia, Jaipur vs. DCIT Cir-6, Jaipur

In the result, this appeal of the assessee is allowed

ITA 902/JPR/2024[2016-17]Status: DisposedITAT Jaipur17 Mar 2025AY 2016-17

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

For Appellant: Shri Vivek Bhargav, C.AFor Respondent: Shri. Anup Singh, Addl.CIT a

Section 143(2)Section 250

head. v. In limited scrutiny cases enquiry shall be restricted only on the issues of limited scrutiny. vi. Only after conversion of case to complete scrutiny and after following the procedure outlined above the A.O. may examined the issues other than limited scrutiny issues. v. The A.O. shall intimate ... assessee regarding conducting complete scrutiny. 8 ITA No. 902./JPR/2024 Suchita Bhatia vs. DCIT. vi. The provisions of Sec. 144A should be invoked in suitable cases. vii. To prevent the roving and fishing enquiries, such cases should be picked up for review and inspection by administrative authorities. In my case

Dashrath Kumar Sharma, Jpr, Jaipur vs. ITO WD 7(4), Jpr, Jaipur

ITA 647/JPR/2024[2014-15]Status: DisposedITAT Jaipur17 Mar 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं./ITA No. 647/JP/2024 निर्धारण वर्ष / Assessment Year : 2014-15 Shri Dashrath Kumar Sharma 73, Pancholiya Ka Mohalla, Kanota, Jaipur – 303 012 बनाम The ITO Vs. Ward 7(4) Jaipur प्रत्यर्थी / Respondent स्थायी लेखा सं./ जीआईआर सं./PAN/GIR No.: EAJPS 0594A अपीलार्थी / Appellant निर्धारिती की ओर से / Assessee by : Shri Mahendra Gargieya, Advocate & राजस्व की ओर से / Revenue by Shri Hemang Gargieya, Advocate :

For Appellant: Shri Mahendra Gargieya, Advocate &For Respondent: Shri Arvind Kumar, CIT-DR

Section 139(1)Section 143(2)Section 143(3)Section 234ASection 56(2)(vii)Section 68

Looking to the discrepancies and huge additions in the assets, proposal for conservation of the case from limited to complete scrutiny was made before the Principal Commissioner of Income Tax, III, Jaipur was made on 04.10.2016 by the ld. AO and the same was approved

M/S. Nandi Engineering Limited, Bengaluru vs. Assistant Commissioner of Income Tax, Circle-5(1)(1), Bengaluru

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

ITA 1942/BANG/2024[2017-18]Status: DisposedITAT Bangalore14 Mar 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Sri H. Siva Prasaad Reddy, A.RFor Respondent: Sri Netrapal M.S., D.R

Section 143(2)Section 143(3)Section 154Section 234BSection 234DSection 250Section 270ASection 37(1)Section 68

sources amounting to Rs.47,31,203/- was omitted to be considered in the computation of income by inadvertence. Thereafter, the case was selected for complete scrutiny and accordingly notices u/s 143(2) as well as 142(1) of the Act was issued along with the questionnaire requesting the assessee

Devi Dutt Agarwal, Jaipur vs. Assessment Unit, Jaipur

In the result the appeal of the assessee is allowed

ITA 1375/JPR/2024[2020-21]Status: DisposedITAT Jaipur13 Mar 2025AY 2020-21

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Appellant: Mr. Vikash Rajvanshi, CAFor Respondent: Mr. Gautam Singh Choudhary, JCIT

Section 10Section 250

thereafter a revised return also on 05.05.2021 declaring total income at Rs. 11,81,550/-. The case of the assessee was selected for complete scrutiny under CASS for the following reasons: 1. Salary income shown under TDS schedule of ITR is higher than the salary income shown under Part

Hanning Motors India Private Limited, Vadodara vs. The Dy.CIT, Circle-1(1)(1), Vadodara

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

ITA 1931/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad13 Mar 2025AY 2017-18

For Appellant: Revenue by

Section 143(3)Section 92C

dishwashers. The assessee filed its return of income on 28.11.2017, declaring a business loss of Rs.21,48,541/-. The case was selected for Complete Scrutiny under CASS, and notices were issued under Sections 143(2) and 142(1) of the Act. Since the assessee had international transactions with Associated Enterprises

ITO, Ward-2(1), Ludhiana vs. Ashwani Kumar Jain, Ludihana

In the result, appeal of the Revenue is dismissed

ITA 1083/CHANDI/2024[2022]Status: DisposedITAT Chandigarh12 Mar 2025

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Balbir Khanna, AdvocateFor Respondent: Shri Vivek Vardhan, Addl.CIT Sr.DR

Section 115BSection 142(1)Section 143(2)Section 69C

filed his return of income on 05.11.2022 declaring taxable income at Rs.48,75,940/-. The case of the assessee was selected for complete scrutiny and a notice under Section 143(2) was issued and served upon the assessee. The ld. AO thereafter issued questionnaire under Section

Govindji Budhaji Thakor, Ahmedabad vs. The ITO, Ward-3(3)(2), Ahmedabad

In the result, the appeal of the Assessee is allowed for statistical

ITA 87/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad12 Mar 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं/Ita No.87/Ahd/2025 निर्धारण वर्ष / Assessment Year : 2017-18 Govindji Budhaji Thakor The Ito Shakar Bhuwan बनाम / Ward-3(3)(2) Makarbiya Wad V/S. Ahmedabad – 380 015 B/H. Karnavati Club S.G. Highway, Mohmedpura Ahmedabad – 380 058 स्थायी लेखा सं./Pan: Apopc 8837 L (अपीलार्थी/ Appellant) (प्रत्यर्थी / Respondent) Assessee By: Shri Manish J. Shah & Rushin Patel, Ars Revenue By : Shri Rignesh Das, Sr.Dr सुनवाई की तारीख /Date Of Hearing : 11/03/2025 घोषणा की तारीख / Date Of Pronouncement: 12/03/2025 आदेश/Order Per Makarand V. Mahadeokar, Am: This Appeal By The Assessee Is Directed Against The Order Dated 22.02.2024, Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”], For The Assessment Year (Ay) 2017-18, Arising Out Of The Ex-Parte Assessment Order Dated 19/11/2019 Passed Under Section 144 Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act"], By The Income Tax Officer, Ward- 3(3)(2), Ahmedabad [Hereinafter Referred To As “Ao”].

For Appellant: Shri Manish J. Shah &For Respondent: Shri Rignesh Das, Sr.DR

Section 142(1)Section 143(2)Section 144Section 250Section 270ASection 271ASection 69A

assessee filed his return of income for A.Y. 2017-18 declaring an income of ₹3,93,060/-. The case was selected for complete scrutiny under CASS. The AO issued a notice under Section 143(2) of the Act dated 24.09.2018 through ITBA, which was duly served on the assessee. Subsequent

Nileshbhai Savjibhai Patel, Ahmedabad vs. The Pr. CIT-3, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 214/AHD/2022[2017-18]Status: DisposedITAT Ahmedabad12 Mar 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Biren Shah & Shri G. M. Thakor. A.RsFor Respondent: Shri Prathvi Raj Meena, CIT DR

Section 263Section 68

return of income for assessment year 2017-18, declaring total income of ₹72,33,800/-. Thereafter, the case of the assessee was selected for complete scrutiny and the assessment order was passed on 31-12-2019 assessing total income of the assessee at ₹3,23,85,620/- by making addition

ACIT, New Delhi vs. M/S. Bbc World India Pvt. Ltd., New Delhi

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

ITA 3489/DEL/2016[2008-09]Status: DisposedITAT Delhi12 Mar 2025AY 2008-09

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahmandcit, Circle 7 (1), Vs. Fmi Automotive Components Private Limited, Delhi. Plot No.1, Subplot 4, 5, 8 & 9 Msil, Supplier Park, Phase 3A, Imt Manesar, Gurgaon – 1222 050 (Haryana). (Pan :Aabcf1682P) (Appellant) (Respondent) Assessee By :Shri S.K. Agarwal, Ca Revenue By :Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing : 24.06.2025 Date Of Order : 22.09.2025 O R D E R Per S. Rifaur Rahman: 1. The Revenue Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 30.05.2024 For The Assessment Year 2017-18 Raising Following Grounds Of Appeal :- “1. Whether On The Facts & Circumstances Of The Case & In Law, The Ld Nfac Has Erred In Allowing The Appeal Of The Assessee By Deleting The Addition Made By The Ao Amounting To Rs.5,90,59,019/- On Account Of Disallowance Of Foreign Exchange Loss On Account Of Plant & Machinery.

For Appellant: Shri S.K. Agarwal, CAFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR

Section 143(1)Section 143(2)Section 41

return was processed under section 143(1) of Income Tax Act, 1961 (for short ‘the Act’). The case of the assessee was selected for complete scrutiny through CASS with the reasons “Opening Written Down Value of fixed assets as per ITR of current year is greater than closing Written Down

Condis India Healthcare Private Limited, Thiruvananthapuram vs. ACIT, Circle-1(1), Thiruvananthapuram

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

ITA 296/COCH/2024[2018-2019]Status: DisposedITAT Cochin11 Mar 2025AY 2018-2019

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.Assessment Year : 2018-19

For Respondent: Shri Rajakannan

Section 14A

brief facts of the case are that the assessee filed their return of income on 06/10/2018 and thereafter their case was selected for complete scrutiny under CASS. The assessee also filed response to the various notices issued by the AO and the AO not satisfied with the explanations had come

Rajesh Mathew, Ernakulam vs. ITO, Ward 1 & Tps Aluva, Aluva

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

ITA 293/COCH/2024[2016-17]Status: DisposedITAT Cochin11 Mar 2025AY 2016-17

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.Assessment Year : 2016-17

For Appellant: NoneFor Respondent: Smt. Leena Lal, Snr. AR

Section 143(3)Section 144Section 263Section 68

civil contractor and he filed the return of income on 28/02/2017. Thereafter the case of the assessee was selected under CASS for complete scrutiny and assessment order u/s. 143(3) of the Act was passed on 18/12/2018 in which the AO accepted the returned income. Thereafter, the PCIT, Kochi under

Assistant Commissioner of Income Tax Circle- 3(4) Mumbai, Mumbai vs. The Shipping Corporation of India Limited, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 1971/MUM/2024[2018-2019]Status: DisposedITAT Mumbai11 Mar 2025AY 2018-2019

Bench: Shri Amarjit Singhshri Sandeep Singh Karhail

For Appellant: Shri Nitesh Joshi a/w Ms. Samiksha SaveFor Respondent: Shri Himanshu Joshi - Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 144BSection 250Section 28Section 43C

ITAs No.1751 & 1971/Mum/2024 (A.Ys. 2018-19) 3 28/11/2018 declaring a total income of Rs.161,55,42,230. The return of income was selected for complete scrutiny under CASS and statutory notices under section 143(2) and section 142(1) were issued and served on the assessee. The Assessing Officer

The Shipping Corporation of India, Mumbai vs. Dy Comm of Income Tax-3(4), Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 1751/MUM/2024[2018-19]Status: DisposedITAT Mumbai11 Mar 2025AY 2018-19

Bench: Shri Amarjit Singhshri Sandeep Singh Karhail

For Appellant: Shri Nitesh Joshi a/w Ms. Samiksha SaveFor Respondent: Shri Himanshu Joshi - Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 144BSection 250Section 28Section 43C

assessee filed its return of income on 28/11/2018 declaring a total income of Rs.161,55,42,230. The return of income was selected for complete scrutiny under CASS and statutory notices under section 143(2) and section 142(1) were issued and served on the assessee. The Assessing Officer

Income Tax Officer, Ward 1(3)(1), Surat vs. Dhiraj Sons Super Market, Surat

In the result, ground No. 2 is also dismissed

ITA 553/SRT/2024[2017-18]Status: DisposedITAT Surat10 Mar 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 553/Srt/2024 (Ay 2017-18) (Physical Court Hearing) Income Tax Officer, Ward- Dhiraj Sons Super Market, Surat 1(3)(1), Surat, Room No.203, C/O Dhiraj Sons Super Store, बनाम Income Tax Office, Anavil Samarth Sarathi Apartment, Parle, Vs Building, Adajan, Surat-395 009 Point, Surat-395 007 [Pan : Aaifd 6720 A] अपीलाथ"/Appellant ""थ" /Respondent

Section 143(3)Section 145(3)Section 254(1)Section 69A

store. The assessee filed its return of income for assessment year 2017-18 declaring loss of Rs.1,83,220/-. The case was selected for complete scrutiny to examine the issue of “reduction in profit because of application of income computation & disclosures standard”. During assessment, the Assessing Officer (AO), on perusal

Income Tax Officer, Ward-2(1), Vijayawada vs. Ahmed Ejaz, Vijayawada

In the result, appeal filed by the Revenue is dismissed

ITA 462/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam07 Mar 2025AY 2017-18

Bench: Shri K Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. 462/Viz/2024 (ननधधारण वर्ा / Assessment Year : 2017-18) Income Tax Officer, Vs. Ahmed Ejaz, Ward-2(1), Vijayawada. Vijayawada. Pan: Aakpe6675R (अपीलधथी/ Appellant) (प्रत्यथी/ Respondent) अपीलधथी की ओर से/ Assessee By : Sri Mv Prasad, Ar प्रत्यधथी की ओर से / Revenue By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Sri MV Prasad, ARFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 143(3)Section 153C

procedure viz., recording satisfaction for evasion of tax and getting prior approval of the Pr. Commissioner of Income Tax to convert the case into complete scrutiny. 2. The Ld. CIT(A) erred in holding that the provisions of section 153C of the Act are applicable to the assessee whereas ... assessee even though he has not denied the fact that the AO recorded his satisfaction for conversion of the assessee’s case for complete scrutiny since there was evasion of tax. 6. Any other ground that may be urged at the time of hearing.” 4 3. The only issue contested

Kapil Taneja, Jaipur vs. ACIT Circle 3, Jaipur

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

ITA 13/JPR/2025[2016-17]Status: DisposedITAT Jaipur07 Mar 2025AY 2016-17

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

For Appellant: Shri Tarun Mittal, C.AFor Respondent: Mrs. Swapnil Parihar, JCIT-DR

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

income declaring total income of Rs.54,30,550/- on 17.10.2016. After filling of ITR the case of the assessee was selected under CASS for complete scrutiny. Notice u/s 143(2) of the IT Act was issued through ITBA on 03.07.2017. On 06.08.2018 notice ... year under consideration was filed by assessee on 17.10.2016 declaring total income at Rs. 54,30,550/- . The case of assessee was selected for complete scrutiny under CASS. Various details and information as sought by ld.AO were furnished and assessment was concluded after making following additions: S.No Addition Made

Assistant Commissioner of Income-Tax, Circle-2(1)(1), Ahmedabad vs. Jewel World, Ahmedabad

In the result, the appeal of the Revenue stands dismissed

ITA 63/AHD/2024[2017-2018]Status: DisposedITAT Ahmedabad07 Mar 2025AY 2017-2018

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.63/Ahd/2024 िनधा"रण वष" /Assessment Year : 2017-18 Assistant Commissioner Of Jewel World बनाम/ Income-Tax 5, Balaji Heights V/S. Circle-2(1)(1) Swagat Cross Road Ahmedabad – 380 015 Nr. Lal Bungalows Cg Road, Ahmedabad-380 009 "थायी लेखा सं./Pan:Aajfj 5833 H अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri M.K. Patel, Advocate Revenue By : Shri Kavan Limbasiya, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 05 /03/2025 घोषणा की तारीख /Date Of Pronouncement: 07 /03/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: This Appeal By The Revenue Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “The Cit(A)”], Dated 06.12.2023, For The Assessment Year (Ay) 2017-18, Whereby The Cit(A) Deleted The Addition Of Rs.5,61,85,000/- Made By The Assessing Officer (Ao) Under Section 69A Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act”]. Asst.Cit Vs. Jewel World Asst. Year : 2017-18

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri Kavan Limbasiya, Sr.DR

Section 143(1)Section 271ASection 69A

declaring an income of Rs.42,67,860/-, which was processed under Section 143(1) of the Act. The case was selected for complete scrutiny under CASS, and notices under Sections 143(2) and 142(1) of the Act were issued. During the assessment proceedings, the AO observed that the assessee

Ariba Technologies India Pvt Ltd, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-1(1)(1), Bengaluru

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

ITA 1587/BANG/2024[AY 2020-21]Status: DisposedITAT Bangalore07 Mar 2025

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Mr. Aliasgar Rampurawala, C.AFor Respondent: Ms. Nandini Das, CIT (DR)

Section 143(3)Section 144C(5)Section 92C

assessee provided Software development and IT Enable services to the associated enterprises along with other international transactions. 5.1 The assessee was selected for complete scrutiny under CASS to examine the various issues. During the scrutiny assessment reference under section 92CA(1) of the Act was made, for the computation

ACIT, New Delhi vs. Shri Hridey Vikram Bhatia, New Delhi

The appeal is allowed

ITA 3173/DEL/2016[2011-12]Status: DisposedITAT Delhi07 Mar 2025AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 2018-19 Vs. Sh. Suresh Kumar Goyal, Acit, Circle-49(1), A-1/102, Ground Floor, New Delhi Janak Puri, Delhi Pan: Aaapg4996R (Appellant) (Respondent) Assessee By None Department By Sh. Manish Gupta, Sr. Dr

Section 143(3)Section 68Section 80G

same money was received back as loan advanced by M/s Golden Steel to appellant. The instant case was selected in CASS under complete scrutiny to examine the issue ‘Refund Claim and Unsecured Loan’. The scrutiny assessment was completed u/s 143(3) r.w.s. 144B of the Act on 10.05.2021 by making