“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

M/S Funidea Vinimay Pvt. Ltd., Kolkata vs. I.T.O., Ward-5(1), Kolkata

The appeal of the assessee is allowed

ITA 2583/KOL/2024[2017-18]Status: DisposedITAT Kolkata28 Feb 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.2583/Kol/2024 Assessment Year: 2017-18 M/S Funidea Vinimay Pvt. Ltd.…………………………………..….……….Appellant 2, Lal Bazar Street, 1St Floor, Kolkata -1. [Pan: Aabcf9340C] Vs. Ito, Ward-5(1), Kolkata...……..............................……........……...…..…..Respondent Appearances By: Shri Manoj Kataruka, Advocate, Appeared On Behalf Of The Assessee. Shri Sailen Samadder, Addl. Cit- Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : February 27, 2025 Date Of Pronouncing The Order : February 28, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 11.12.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Assessment Year 2017-18 By Declaring Total Income Of Rs.33,511/-. The Case Of The Assessee Was Selected For Scrutiny Assessment Under Limited Scrutiny Criteria For The Reason Of Selection Of Low Income Compared To High Loans/Advances/Investment In Shares Appearing In Balance Sheet & Expenses Debited To P&L A/C For Earning Exempt Income As Per Schedule Bp Of Itr Is Significantly Lower As Compared To Investments Made To Earn Exempt Income. Subsequently, Notice U/S 143(2) Of The Act Was Issued To The Assessee & Also Notice

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

further I.T.A. No.2583/Kol/2024 Assessment Year: 2017-18 M/s Funidea Vinimay Pvt. Ltd stated that the assessment was conducted under limited scrutiny without converting into complete scrutiny with due approval from the competent authority rendering the order erroneous. Besides that while passing the order, the ld. CIT(A) also erred ... discrepancies were pointed out hence the additions made were not legally sustainable. We also note that conducting assessment under limited scrutiny without conversion to complete scrutiny was not in accordance with law and the assessee has submitted sufficient documents before the authorities below including audited account, bank statement and other

Deputy Commissioner of Income Tax, Circle-1, Thane, Ashar It Park, Thane West vs. Darshan Enterprises, Ghodbunder Road, Thane

In the result, appeal of the Revenue is dismissed

ITA 4969/MUM/2024[2018-19]Status: DisposedITAT Mumbai28 Feb 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 68

assessee firm had filed its return of income declaring total income of Rs. 8,72,88,8880/-. Later, the case was selected for complete scrutiny under the E-assessment scheme, 2019 and assessment order was passed u/s. 143(3) on 23.06.2021 assessing total income

ACIT, New Delhi vs. M/S Jubilant Enpro Pvt. Ltd., New Delhi

In the result, appeal of assessee is allowed

ITA 3615/DEL/2011[2008-09]Status: DisposedITAT Delhi28 Feb 2025AY 2008-09

Bench: Shri Yogesh Kumar U.S. & Shri Naveen Chandrarakshit Estates Private Vs. Income Tax Officer, Hsiidc Limited. Building, Vanijya Nikunj, Plot No. 11, Basement, J 2.1, Udhyogvihar, Phase-V, Sector 83, Gurgaon, Haryana Gurgaon, Haryana Pan: Aagcr0135G Appellant Respondent Assessee By Sh. Ramesh Chander, Adv Revenue By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 24/09/2025 Date Of Pronouncement 29/10/2025

Section 131Section 143(2)Section 143(3)

Long Term Liabilities in 6 Rakshit Estates Pvt. Ltd. Vs. ITO the Balance Sheet as on 31.3.2017. The appellant's case was selected for Complete Scrutiny under CASS and notice u/s 143(2) dated 08.08.2018 was issued. Further, statutory notices were issued from time to time, requiring the appellant

Manojbhai Arvindbhai Parekh, Rajkot vs. Assistant Commissioner of Income Tax, Circle - 2(1), Rajkot

In the result, appeal filed by the assessee, is partly allowed in above terms

ITA 385/RJT/2023[2017-18]Status: DisposedITAT Rajkot27 Feb 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 385 /Rjt/2023 ("नधा"रण वष"/Assessment Year: (2017-18) Manojbhai Arvindbhai Parekh The Acit Of I. T. Circle – 2(1), Shreeji Giriraj Trading, 19-Giriraj Vs. Rajkot – 360001 Chamber, Old Gadhiwas Soni Bazar, Rajkot – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acypp1471C (अपीलाथ"/Assessee) (""यथ"/Respondent)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr.DR

Section 115BSection 142(1)Section 143(1)Section 143(2)Section 143(3)Section 68

return of income has been processed u/s 143(1) of the Income Tax Act, 1961. Later on, the assessee`s case was selected for complete scrutiny under CASS. The notice u/s. 143(2) of the Act was issued on 10.08.2018 and duly served upon the assessee. Further, various notice

Rakesh Bhojani, Siyaganj Indore vs. Assistant Commissioner of Income Tax Circle -4(1), Indore, Cgo Complex

Appeal is allowed

ITA 811/IND/2024[2017-18]Status: DisposedITAT Indore27 Feb 2025AY 2017-18

Bench: Shri B.M. Biyani & Shri Udayan Das Gupta

Section 143(2)Section 143(3)Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND SHRI UDAYAN DAS GUPTA

Sanjeev Kumar Kathuria, Yamuna Nagar vs. Income Tax Officer Ward 1, Yamunanagar

In the result, the appeal of the assessee is allowed

ITA 329/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh27 Feb 2025AY 2018-19

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Ajay Jain, C.AFor Respondent: Smt. Kusum Bansal, CIT, DR

Section 143(2)Section 143(3)Section 263Section 40A(3)

that the assessee filed his return of income declaring total income of Rs. 69,52,590/-. Subsequently, return of income was selected for complete scrutiny and notice under section 143(2) and 142(1) were issued alongwith questionnaire, and after taking into consideration the submission filed by the assessee ... filed by the assessee on 29.10.2018 declaring total income of Rs. 69,52,490/-. The case was selected for complete scrutiny on the issue of 'Share Capital/Other Capital'. The assessee had sold a residential property, 139, Masjid Moth, Uday Park, New Delhi, measuring 180 sq.m

Sai Projects & Systems Pvt Ltd., Bengaluru vs. Income Tax Officer, Ward-6(1)(1), Bengaluru

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

ITA 2622/BANG/2024[2018-19]Status: DisposedITAT Bangalore26 Feb 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2018-19

For Appellant: Shri Dayanad K, CA

Section 144

return of income and shown a loss of Rs. 1,82,80,191/-. Thereafter the case was Page 2 of 4 selected for complete scrutiny and the AO sought for explanations and not satisfied with the said explanations had rejected the books of accounts and estimated the income by adopting

Al Rasheed Charitable Society, Haryana vs. JCIT, Exemptions, Chandigarh

The appeal of the assessee is allowed as and by way of remand for fresh decision in

ITA 843/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh25 Feb 2025AY 2016-17

For Respondent: Shri Parikshit Aggarwal, C.A (Virtual)

Section 143(1)Section 143(3)Section 246ASection 250Section 253Section 271Section 271(1)(c)Section 274

income and the same was processed under section 143(1) of the Act. The case of the assessee was selected through CASS for complete scrutiny. After the issue of statutory notices, the AO examined the details. The AO has completed the assessment u/s.143(3) of the Act vide an order

Gaurav Goel, Chandigarh vs. ITO, Ward 4(3), Chandigarh

In the result, the appeal of the assessee stands allowed

ITA 132/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh24 Feb 2025AY 2017-18

Bench: Shri Vikram Singh Yadav & Shri Paresh M. Joshiआयकर अपील सं./ Ita No. 132/Chd/2024 "नधा"रण वष" / Assessment Year: 2017-18 Gaurav Goel, Vs. The Ito, बनाम H. No. 1676, Sector 33-D, Ward 4(3), Chandigarh Chandigarh "थायी लेखा सं./Pan No: Ahgpg3162Q अपीलाथ"/ Assessee ""यथ"/ Repsondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Jaspal Sharma, Advocate राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Jcit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 17.12.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 24.02.2025 आदेश/Order Per Paresh M. Joshi, Jm :

For Appellant: Shri Jaspal Sharma, AdvocateFor Respondent: Shri Vivek Vardhan, JCIT, Sr. DR

Section 142(1)Section 143(1)Section 143(2)Section 250Section 253

income at Rs. 10,59,210/-. This return was processed u/s 143(1) of the Act. 2.2. The case of Assessee was selected for Complete Scrutiny through CASS. 2.3 Statutory Notice u/s 143(2) was issued on 09.08.2018 which was duly served upon the Assessee. The case was however, transferred

The Tambaram Co-Op Urban Bank Ltd. Jj46, Chennai vs. ACIT, Ncc-22(1), Tambaram

In the result the appeal of the assessee is allowed

ITA 3178/CHNY/2024[2017-18]Status: DisposedITAT Chennai24 Feb 2025AY 2017-18

Bench: Shri George George K, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं/.Ita No.: 3178/Chny/2024 िनधा" रणवष" / Assessment Year: 2017-18 The Tambaram Co-Operative Acit Urban Bank Limited Jj 46 V. Non-Corporate Circle-22(1) 14, Venkattesan Street West Tambaram. Tambaram, Tambaram-600045. [Pan:Aaaat-0010-A] (अपीलाथ"/Appellant) (""यथ"/Respondent) : Ms.N.V.Lakshmi, Advocate अपीलाथ"क"ओरसे/Appellant By ""यथ"क"ओरसे/Respondent By : Ms.Gauthami Manivasagam, Jcit सुनवाईकीतारीख/Date Of Hearing : 19.02.2025 घोषणाकीतारीख/Date Of Pronouncement : 24.02.2025

For Respondent: Ms.Gauthami Manivasagam, JCIT

Section 143(3)Section 37(1)

filed its return of income for the A.Y.2017-18 on 12.10.2017 by declaring a total income of Rs.96,10,290/-. The case was selected for complete scrutiny under CASS and issued statutory notices to the assessee. On perusal of documents and submissions made by the assessee, the AO found that

Assistant Commissioner of Income Tax, Madurai vs. Ramco Industries Limited, Madurai

Appeals of the revenue stand dismissed

ITA 2884/CHNY/2024[2020]Status: DisposedITAT Chennai24 Feb 2025

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita Nos.2883 & 2884/Chny/2024. (िनधा"रणवष" / Assessment Years: 2018-2019 & 2020-2021) The Assistant Commissioner Of Vs. Ramco Industries Limited, Income Tax, 47, Psk Nagar, Corporate Circle, Rajapalayam 626 108. Madurai [Pan Aaacr 5284J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. S. Muralidhar & Shri J. Prabhakar, F.C.As. ""यथ" क" ओर से /Respondent By : Shri. R. Bhoopathi, Addl. Cit. सुनवाई क" तार"ख/Date Of Hearing : 06.02.2025 घोषणा क" तार"ख /Date Of Pronouncement : 24.02.2025 आदेश / O R D E R Per Manu Kumar Giri ()

For Appellant: Shri. S. Muralidhar and Shri JFor Respondent: Shri. R. Bhoopathi, Addl. CIT

Section 115JSection 143(3)Section 14A

Income for AY 2018-19 on 31-10-2018 declaring a total income of Rs. 15,38,59,210/-. The case was selected for complete scrutiny. The company had earned exempt income of Rs. 15,23,36,353/-in the form of dividends from domestic companies. The assessee had identified

Assistant Commissioner of Income Tax, Madurai vs. Ramco Industries Limited, Rajapalayam

Appeals of the revenue stand dismissed

ITA 2883/CHNY/2024[2018]Status: DisposedITAT Chennai24 Feb 2025

For Appellant: Shri. S. Muralidhar and Shri JFor Respondent: Shri. R. Bhoopathi, Addl. CIT

Section 115JSection 143(3)Section 14A

Muthu Thevar Nagarajan, Dindigul vs. ITO, Ward-1., Dindigul

Appeals of the revenue stand dismissed

ITA 2083/CHNY/2024[2018-19]Status: DisposedITAT Chennai24 Feb 2025AY 2018-19

For Appellant: Shri. S. Muralidhar and Shri JFor Respondent: Shri. R. Bhoopathi, Addl. CIT

Section 115JSection 143(3)Section 14A

Edavilangu Service Co-Operative Bank No 3468, Thrissur vs. ITO, Ward-2(1), Thrissur

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 406/COCH/2024[AY 2020-2021]Status: DisposedITAT Cochin21 Feb 2025

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Smt. Leena Lal, Snr. ARFor Respondent: None

Section 2(1)Section 80Section 80PSection 80P(2)Section 80P(2)(a)

income on 07/12/2018 declaring a Nil income and claimed the deduction u/s. 80P(2) of the Act. Thereafter the case was selected for complete scrutiny and the assessment was completed in which the AO had denied the deduction claimed u/s. 80P(2)(a) of the Act for the reason that

Edavilangu Service Co-Operative Bank Ltd No 3468, Thrissur vs. ITO, Ward-2(1), Thrissur

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 405/COCH/2024[2017-2018]Status: DisposedITAT Cochin21 Feb 2025AY 2017-2018

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Smt. Leena Lal, Snr. ARFor Respondent: None

Section 2(1)Section 80Section 80PSection 80P(2)Section 80P(2)(a)

The Kumbakonam Central Cooperative Bank, Kumbakonam vs. CIT (Appeals)

In the result the appeals of the assessee are decided as under:-

ITA 584/CHNY/2024[2020-21]Status: DisposedITAT Chennai21 Feb 2025AY 2020-21

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.583/Chny/2024, Assessment Year: 2013-14 आयकर अपील सं./Ita No.584/Chny/2024, Assessment Year: 2020-21 The Kumbakonam Central Cooperative Bank, Vs. Deputy Commissioner Of No.150, T.S.R. Big Street, Income Tax (Appeals), Kumbakonam, Circle-1, Kumbakonam. Tamil Nadu-612001. [Pan: Aaaat0148B] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant)

For Appellant: Mr.Varun Ranganathan,Advocate for Mr.Ravi Kannan, AdvocateFor Respondent: A.Sasikumar, CIT

Section 143(3)Section 147Section 250Section 36(1)(viia)

case. Return declaring income of Rs.9,54,13,800/- was filed by the assessee on 03.12.2020. The case was completed under the complete scrutiny category by order u/s 143(3) dated 08.09.2022 by the Ld. AO in the impugned order. As it was complete scrutiny category case

The Kumbakonam Central Cooperative Bank, Kumbakonam vs. CIT (Appeals)

In the result the appeals of the assessee are decided as under:-

ITA 583/CHNY/2024[2013-14]Status: DisposedITAT Chennai21 Feb 2025AY 2013-14

For Appellant: Mr.Varun Ranganathan,Advocate for Mr.Ravi Kannan, AdvocateFor Respondent: A.Sasikumar, CIT

Section 143(3)Section 147Section 250Section 36(1)(viia)

Three Seasons Ware Housing, Kakinada vs. Income Tax Officer, Ward-1, Kakinada

In the result, appeal of the assessee is allowed

ITA 286/VIZ/2023[2018-19]Status: DisposedITAT Visakhapatnam20 Feb 2025AY 2018-19

Bench: Shrik Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./ I.T.A.286/Viz/2023 (निर्धारण वर्ा/ Assessment Year: 2018-19) Three Seasons Ware Housing, Vs. Income Tax Officer, Kakinada. Ward-1, Pan: Aajft4738R Kakinada. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थीकीओरसे/ Assessee By : Sri Gvn Hari, Ar प्रत्यधर्थीकीओरसे/ Revenue By : Dr. Satyasai Rath, Cit-Dr

For Appellant: Sri GVN Hari, ARFor Respondent: Dr. Satyasai Rath, CIT-DR

Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 68

return of income on 31/08/2018 admitting a total income of (-) Rs.21,506/- for the AY 2018-19. Subsequently, the case was selected for complete scrutiny for the following reasons viz., (i) investment / advances / loans and (ii) business loss. Accordingly, statutory notices

Gurukul Arsh Kanya Vidhyapeeth, Najibabad, Bijnor, Uttar Pradesh vs. Income Tax Officer (Exemption), Bareily

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

ITA 25/LKW/2025[2018-19]Status: DisposedITAT Lucknow20 Feb 2025AY 2018-19

Bench: Shri Kul Bharatassessment Year: 2018-19 Gurukul Arsh Kanya Income Tax Officer V. Vidhyapeeth (Exemption) Gurukul Arsh Kanya C.R. Building, Kamla Vidhyapeeth, Kotwali Road, Nehru Marg, Civil Lines, Near Shravanpur Nahar Bareily-243001. Najibabad, Bijnor-246763. Pan:Aabtg6651N (Appellant) (Respondent) Appellant By: Shri Sailesh Gupta, Ca Respondent By: Shri Sanjeev Krishna Sharma, Addl Cit(Dr) Date Of Hearing: 17 02 2025 Date Of Pronouncement: 20 02 2025 O R D E R

For Appellant: Shri Sailesh Gupta, CAFor Respondent: Shri Sanjeev Krishna Sharma, Addl

Section 11Section 115BSection 12ASection 142(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144Section 68

thereby a demand of Rs.16,60,380/- was raised after making adjustments. Thereafter, the case was selected for complete scrutiny. A notice u/s 143(2) of the Act was issued on 23.09.2019 another notice u/s 142(1) of the Act along with questionnaire was also issued on 25.11.2020. The Assessing

Deputy Commissioner of Income, Aurangabad vs. Metarolls Ispat Pvt. Ltd, Jalna

ITA 933/PUN/2024[2021-22]Status: DisposedITAT Pune20 Feb 2025AY 2021-22

Bench: Shri R. K. Panda & Ms. Astha Chandra

Section 132Section 133(6)Section 143(1)Section 143(2)

determining the total income of the assessee at Rs.39,48,76,390/-. Subsequently, the case was selected for complete scrutiny and notices u/s 143(2) and 142(1) of the Act were issued and served on the assessee, in response to which the AR of the assessee appeared before