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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

United Futuristic Trade Impex Private Limited, Mumbai vs. Commissioner of Income-Tax (Appeals), National Faceless Appeal Centre (NFAC)

In the result, the present cross-appeal is allowed for statistical purposes

ITA 4219/MUM/2024[2017-2018]Status: DisposedITAT Mumbai29 Nov 2024AY 2017-2018

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailacit, Circle – 8(3)(1) Room No.665A, 6Th Floor, Aayakar Bhavan, Mumbai – 400020 ............... Appellant V/S United Futuristic Trade Impex Pvt. Ltd., Unit No.301, 3Rd Floor, Turf Estate Off Dr. E Moses Road, Shakti Mill Lane Mahalaxmi, Mumbai – 400011, ……………… Respondent Maharashtra Pan : Aabcu7296C United Futuristic Trade Impex Pvt. Ltd., Bajaj Bhavan, 226-Nariman Point, Unit No.301, 3Rd Floor, Turf Estate Off Dr. E Moses Road, Shakti Mill Lane Mahalaxmi, Mumbai – 400011, Maharashtra ……………… Appellant Pan : Aabcu7296C V/S Acit, Circle – 8(3)(1) Room No.665A, 6Th Floor, Aayakar Bhavan, Mumbai – 400020 …………….. Respondent

For Appellant: Shri Satish ModyFor Respondent: Shri Raj Singh Meel, Sr. DR
Section 250

filed its return of income on 07.11.2017 declaring a total income of Rs.49,43,077/-. The return filed by the assessee 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. During the assessment proceedings

ACIT Circle 8(3)(1), Mumbai vs. United Futuristic Trade Impex Pvt. Ltd., Mumbai

In the result, the present cross-appeal is allowed for statistical purposes

ITA 3674/MUM/2024[2017-18]Status: DisposedITAT Mumbai29 Nov 2024AY 2017-18

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailacit, Circle – 8(3)(1) Room No.665A, 6Th Floor, Aayakar Bhavan, Mumbai – 400020 ............... Appellant V/S United Futuristic Trade Impex Pvt. Ltd., Unit No.301, 3Rd Floor, Turf Estate Off Dr. E Moses Road, Shakti Mill Lane Mahalaxmi, Mumbai – 400011, ……………… Respondent Maharashtra Pan : Aabcu7296C United Futuristic Trade Impex Pvt. Ltd., Bajaj Bhavan, 226-Nariman Point, Unit No.301, 3Rd Floor, Turf Estate Off Dr. E Moses Road, Shakti Mill Lane Mahalaxmi, Mumbai – 400011, Maharashtra ……………… Appellant Pan : Aabcu7296C V/S Acit, Circle – 8(3)(1) Room No.665A, 6Th Floor, Aayakar Bhavan, Mumbai – 400020 …………….. Respondent

For Appellant: Shri Satish ModyFor Respondent: Shri Raj Singh Meel, Sr. DR
Section 250

filed its return of income on 07.11.2017 declaring a total income of Rs.49,43,077/-. The return filed by the assessee 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. During the assessment proceedings

Ujwal Fine Homes, Pune vs. The Principal Commissioner of Income Tax -3, Pune

In the result, appeal of the assessee is dismissed

ITA 491/PUN/2024[2018-19]Status: DisposedITAT Pune28 Nov 2024AY 2018-19

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.491/Pun/2024 िनधा"रण वष" / Assessment Year: 2018-19 Ujwal Fine Homes, V The Principal High Bliss, S No.23, Dhayri S Commissioner Of Income Narhe Road, Pune – 411041. Tax, Pune -3, Pune. Pan; Aabfu7293E Appellant/ Assessee Respondent / Revenue Assessee By Shri C.H.Naniwadekar – Ar Revenue By Shri Ajay Kumar Keshari – Cit(Dr) Date Of Hearing 21/11/2024 Date Of Pronouncement 28/11/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Directed Against The Order Of Ld.Principal Commissioner Of Income Tax, Pune-3, Pune U/Sec.263 Of The Income Tax Act, 1961; Dated 09.02.2024 For The A.Y.2018- 19. The Assessee Has Raised The Following Grounds Of Appeal : “1. In Issuing The Notice U/S 263 Of The Income-Tax Act, 1961 For Ay 2018-19

Section 142Section 143(3)Section 171Section 263

income on 10-10-2018 admitting a total income of Rs.11,32,63,182/- vide acknowledgement no 330005791101018. Subsequently the case was selected for 'complete scrutiny' through CASS. 3.1 Notice u/s 143(2) dated 21-09-2019 was issued and served on the assessee through the ITBA system. Further, notice

Sri Varaha Lakshmi Narasimha Swamy Devastanam, Visakhapatnam vs. Assistant Commissioner of Income (Exemption Circle), Vijayawada

In the result, appeal of the assessee is allowed

ITA 430/VIZ/2024[2020-21]Status: DisposedITAT Visakhapatnam28 Nov 2024AY 2020-21

Bench: Shri K. Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.430/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2020-21) Sri Varaha Lakshmi Narasimha Swamy Devstanam V. Asst. Cit #1, Simhagiri Hills, Simhachalam Road Exemption Circle Simhachalam – 530028, Visakhapatnam Income Tax Office C.R. Building “Annex” Andhra Pradesh M.G. Road Vijayawada – 520002 [Pan: Aaals1522P] Andhra Pradesh (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 10Section 10(23)(v)Section 143(2)Section 143(3)Section 80G

Assessee filed its return of income admitting a total income 15,08,700/- for the A.Y. 2020-21. Later, the case was selected for complete scrutiny under CASS. Statutory notices under section 143(2) and 142(1) of the Act were issued and served on the assessee. In response, assessee

Peddini Ashok Kumar, Visakhapatnam vs. Income Tax Officer, Ward-4(1), Visakhapatnam

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

ITA 356/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam28 Nov 2024AY 2017-18

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.356/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2017-18) Peddini Ashok Kumar V. The Income Tax Officer- Ward-4(1) D.No. 49-36-13/1 Income Tax Office Nggo’S Colony, Akkayyapalem Pratyakshakar Bhavan Visakhapatnam – 530016 Mvp Double Road Andhra Pradesh Visakhapatnam – 530017 Andhra Pradesh [Pan: Aqlpp3626L] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

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

income for the A.Y. 2017-18 on 31.10.2017 admitting total income at Rs.7,82,200/-. The case was selected for scrutiny through CASS under Complete Scrutiny Category and accordingly, notice under section 143(2) of the Act was issued and duly served on the assessee. In response, assessee has furnished

Bsm Developers, Jaipur vs. ITO, Ward-4(1), Jaipur

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

ITA 783/JPR/2024[2018-19]Status: DisposedITAT Jaipur28 Nov 2024AY 2018-19

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyalbsm Developers, C/O M/S. Kalani & Co. 5Th Floor, Milestone Building, Gandhi Nagar Turn, Tonk Road, Jaipur – 302 015. Pan No.: Aanfb 1823H ..... Appellant Vs. Ito, Ward-4(1), Jaipur – 302 015. ..... Respondent

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: Ms. Anita Rinesh, JCIT- Ld. Sr. DR
Section 143(3)Section 250

income on 25-08-2018 declaring total income at Rs. 27,49,760/-. The case of the assessee was selected under CASS for complete scrutiny with a specific reason assigned is “Verification of the contract receipts/fees. The assessment of the assessee was completed u/s. 143(3) r.w.s. 144B

Saraswati Educational Society Regd., New Delhi vs. CIT Exemption, Delhi

ITA 1889/DEL/2024[2018-19]Status: DisposedITAT Delhi28 Nov 2024AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

Section 11Section 11(5)Section 263

Income Tax Act, 1961 (‘Act’ for short) and also u/s 80G (5)(vi) of the Act. The case of the Assessee was selected for complete scrutiny on the issue of ‘transaction of Trust with specified persons’. The statutory notices u/s 143(2) and 142(1) of the Act were issued

Income Tax Officer, Ward-9(1), Kolkata vs. Kali Fabrics Private Limited, Kolkata

In the result, appeal of the revenue is dismissed

ITA 291/KOL/2024[2018]Status: DisposedITAT Kolkata27 Nov 2024

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm]

Section 143(2)Section 143(3)Section 36Section 36(1)(iii)

brief are that the assessee filed its return of income on 30.10.2018 declaring gross income of Rs.1,44,27,515/- which was selected for complete scrutiny. The AO issued notices u/s. 143(2) and 142(1) of the Act along with questionnaire which was duly replied by the assessee

Paras Jain HUF, New Delhi vs. ITO Ward - 43(1), New Delhi

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

ITA 3436/DEL/2024[2017-18]Status: DisposedITAT Delhi27 Nov 2024AY 2017-18

Bench: Shri S.Rifaur Rahman & Shri Sudhir Kumarparas Jain Huf, Vs. Ito, Ward 43 (1), 158, Sandesh Vihar, Pitampura, New Delhi. New Delhi – 110 034. (Pan : Aanhp8779E) (Appellant) (Respondent) Assessee By : Shri Saurav Rohatgi, Ca Shri Rajat Mittal, Ca Revenue By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing : 19.11.2024 Date Of Order : 27.11.2024 O R D E R Per S.Rifaur Rahman,Am: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax Appeals/National Faceless Appeal Centre (Nfac) (Hereinafter Referred To 'Ld. Cit (A)' Dated 25.03.2024 For Ay 2017-18. 2. Brief Facts Of The Case Are, Paras Jain (Huf), The Assessee Has Filed Its Return Of Income For The Year Under Consideration Declaring Income Of Rs.4,35,910. The Assessee Was The Proprietor Of M/S. Aaradhya Jewellers & Deals In The Trading Of Gold & Diamond Jewellery. The Return Of Income Was Processed U/S 143(3) Of The Income-Tax Act, 1961 (For Short ‘The Act’) & Thereafter, The Case

For Appellant: Shri Saurav Rohatgi, CAFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 143(2)Section 143(3)Section 68

income was processed u/s 143(3) of the Income-tax Act, 1961 (for short ‘the Act’) and thereafter, the case 2 was selected for complete scrutiny through CASS. The assessee has deposited cash of Rs.44,50,000/- in his bank account during the demonetization period. The Assessing Officer issued

ACIT, Circle-13(1), New Delhi vs. Kamdhenu Ltd, New Delhi

In the result, the appeal filed by the Revenue and cross objections filed by the assessee are dismissed

ITA 1311/DEL/2023[2018-19]Status: DisposedITAT Delhi27 Nov 2024AY 2018-19

Bench: Shri S.Rifaur Rahman & Shri Yogesh Kumar U.S.Acit, Circle-13(1), Vs. M/S Kamdhenu Limited, New Delhi L-311, Khasra No. 724, Street No. 7, Mahipalpur Extension, New Delhi – 110 037. (Pan : Aaack7155M) Co No.24/Del/2024 (In Ita No.1311/Del/2023) (Assessment Year: 2018-19) M/S Kamdhenu Limited, Vs. Acit, Circle 13(1), L-311, Khasra No. 724, New Delhi Street No. 7, Mahipalpur Extension, New Delhi – 110 037 (Pan : Aaack7155M) (Appellant) (Respondent) Assessee By : Shri Sanjay Garg, Ca, Shri Udyan Garg, Ca, Shri Akarsh Garg, Advocate Shri Harish Aggarwal, Cfo Revenue By : Shri Dayainder Singh Sidhu, Cit (Dr) Date Of Hearing : 16.10.2024 Date Of Order : 27.11.2024 O R D E R Per S. Rifaur Rahman,Am:

For Appellant: Shri Sanjay Garg, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT (DR)
Section 143Section 145(2)Section 145(3)

case are, the assessee filed its return of income on 29.09.2018 declaring total income of Rs.27,85,77,150/-. The case was selected for complete scrutiny under CASS for verification of issues, like, claim of any other amount allowable as deduction in Schedule BP, stock valuation, ICDS compliance and adjustment

The Thanthi Trust, Chennai vs. CIT(Exemptions), Chennai

In the result, the appeal of the assessee is allowed

ITA 1369/CHNY/2024[2018-19]Status: DisposedITAT Chennai26 Nov 2024AY 2018-19

Bench: Shri Aby T Varkey, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1369/Chny/2024 िनधा"रणवष" / Assessment Year: 2018-19 Commissioner Of Income Tax The Thanthi Trust, V. (Exemptions), No. 86, Evk Sampath Road, Chennai – 600 034. Vepery, Chennai – 600 007. [Pan: Aaatt-0038-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. V.S. Jayakumar, Sr. Advocate For Shri.Mudit Bohara, Advocate & Shri. K.R. Adivarahan, Ca ""यथ"क"ओरसे/Respondent By : Shri. Nilay Baran Som, Cit सुनवाई क" तारीख/Date Of Hearing : 30.08.2024 घोषणा क" तारीख/Date Of Pronouncement : 26.11.2024 आदेश /O R D E R

For Appellant: Shri. V.S. Jayakumar, Sr. Advocate for Shri.Mudit Bohara, Advocate and Shri. K.RFor Respondent: Shri. Nilay Baran Som, CIT
Section 11(4)Section 12ASection 143(1)Section 143(2)Section 143(3)Section 263

return of income was processed u/s.143(1) of the Act on 17.11.2019 and refund ordered by NFAC. The case was also selected for complete scrutiny on the following :-3-: ITA. No:1369/Chny/2024 issues and notice u/s.143(2) dated 23.09.2019 was issued to assessee; - Expenditure for charitable or Religious issues - Receipts

Asian Hotels (North) Limited, New Delhi vs. Pr, CIT, Delhi-1, New Delhi

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

ITA 654/DEL/2021[2016-17]Status: DisposedITAT Delhi26 Nov 2024AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek, Judicialmember M/S. Asian Hotels (North) Limited, Vs. Pr.Cit, 1A, Hotel Hyatt Regency, Delhi – 1. Bhikaji Cama Place, New Delhi – 110 066. (Pan: Aaaca0125H) (Appellant) (Respondent) Assessee By : Shri Abhishek Jain, Ca Revenue By : Shri Javed Akhtar, Cit Dr Date Of Hearing : 17.09.2024 Date Of Order : 26.11.2024 O R D E R Per S. Rifaur Rahman, Am : 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Principal Commissioner Of Income-Tax, Delhi-1 (Hereinafter Referred To ‘Ld. Pcit’) Dated 31.03.2021 For Assessment Year 2016-17. 2. Brief Facts Of The Case Are, Assessee Filed Its Return Of Income On 29.09.2016 Declaring A Loss Of Rs.32,48,76,393/-. The Case Was Selected For Complete Scrutiny Under Cass. The Assessment Was Completed Under Section 143 (3)

For Appellant: Shri Abhishek Jain, CAFor Respondent: Shri Javed Akhtar, CIT DR
Section 143Section 143(3)Section 41(1)Section 438

case are, assessee filed its return of income on 29.09.2016 declaring a loss of Rs.32,48,76,393/-. The case was selected for complete scrutiny under CASS. The assessment was completed under section 143 (3) 2 of the Income-tax Act, 1961 (for short ‘the Act’) on 23.11.2019 making

Benazir Begaum, Ariyalur vs. DCIT, Circle-1(1), Trichy

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

ITA 2470/CHNY/2024[2017-18]Status: DisposedITAT Chennai25 Nov 2024AY 2017-18

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita No.2470/Chny/2024 (िनधा"रणवष" / Assessment Year: 2017-2018) Benazir Begaum, Vs. The Deputy Commissioner Of 21,Jjubair Indane Gas Suppliers, Income Tax, G.H. Road, Circle 1(1) Ariyalur Trichy Ariyalur Dist. 621 704. [Pan: Apppb 6037G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri T. Vasudevan, Advocate ""यथ" क" ओर से /Respondent By : Ms. Kavitha, Irs, Addl. Cit. सुनवाई क" तार"ख/Date Of Hearing : 21.11.2024 घोषणा क" तार"ख /Date Of Pronouncement : 25.11.2024 आदेश / O R D E R Per Manu Kumar Giri ()

For Appellant: Shri T. Vasudevan, AdvocateFor Respondent: Ms. Kavitha, IRS, Addl. CIT
Section 143(3)Section 69A

return of income for the A.Y.2017-18 in ITR-3 on 30.03.2018 declaring taxable income of Rs. 15,93,400/-. The case was selected for complete scrutiny under CASS. Several statutory notices/SCN issued by the AO were not responded to by the assessee. After affording the assessee, sufficient opportunity

Darekoppa Krishnaiahshetty Kesha vs. Hetty, Bangalorevs.Income Tax Officer Ward 6(2)(1), Bangalore

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

ITA 1738/BANG/2024[2017-18]Status: DisposedITAT Bangalore25 Nov 2024AY 2017-18

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

For Appellant: Smt. Manasa Ananthan, A.RFor Respondent: Sri Ganesh R. Gale, Standing counsel for department

Rs.15,40,048 (-) Rs.9,74,408/-). The return was processed u/s 143(1) of the Act. Thereafter the case was selected for complete scrutiny through CASS reason being reduction of income in the revised return. Accordingly, notices u/s 143(2) as well as notice

Arvind Ambalal Patel, Ahmedabad vs. The Income Tax Officer, Ward-1(2)(1) (Old Ward-5(2)(2)), Ahmedabad

In the result, appeal of the assessee is allowed

ITA 381/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad22 Nov 2024AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2017-18

Section 115BSection 129Section 133(6)Section 143(2)Section 272A(1)(d)Section 68Section 69A

Section 143(2) of the Income Tax Act, 1961 was issued on 09.08.2013 which was served upon the assessee. The case was selected for complete scrutiny for the reason “abnormal increase in cash deposits during demonetisation period as compared to pre-demonetisation period and large value receipt of repayment

Kamal Deep Singh, Shahjahanpur vs. ITO -1 (4), Shahjahanpur

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

ITA 57/LKW/2024[2017-18]Status: HeardITAT Lucknow19 Nov 2024AY 2017-18

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Kamal Deep Singh V. The Ito-1(4) C/O Sanjay Saxena Shahjahanpur 12, Pratap Enclave Bisrat, G.T. Road Shahjahanpur Tan/Pan:Bizps6787C (Appellant) (Respondent) Appellant By: Shri Sanjay Saxena, C.A. Respondent By: Shri Sanjeev Krishna Sharma, D.R. Date Of Hearing: 13 11 2024 Date Of Pronouncement: 19 11 2024 O R D E R

For Appellant: Shri Sanjay Saxena, C.AFor Respondent: Shri Sanjeev Krishna Sharma, D.R
Section 115BSection 143(3)Section 234BSection 69Section 69A

income for the year under consideration on 20.12.2017, declaring a total income of Rs.6,27,010/-. The case of the assessee was selected for complete scrutiny under CASS for the reason that the assessee ITA No.57/LKW/2024 Page 2 of 6 had deposited cash in his bank accounts during the demonetization

Srimanta Kumar Shit, Purba Medinapore vs. A.C.I.T., Circle - 27(2), Haldia

In the result, the appeal of the assessee is allowed

ITA 1911/KOL/2024[2017-2018]Status: DisposedITAT Kolkata19 Nov 2024AY 2017-2018

Bench: Shri Rajpal Yadav, Vice- & Shri Rajesh Kumari.T.A. No. 1911/Kol/2024 Assessment Year: 2017-2018 Srimanta Kumar Shit,………………...…………Appellant Rangamalaput, Junput-Contai, Purba Medinapore-721450, West Bengal [Pan:Bffps3635Q] -Vs.- Assistant Commissioner Of Income Tax..…Respondent Circle-27(2), Haldia, Basudebpur, Talpukur, Khanjan Chak, Haldia, Midnapore-721101, W.B. Appearances By: Shri S.K. Tulsiyan, Advocate & Lata Goyal, Ca, Appeared On Behalf Of The Assessee Shri Subhendu Datta, Cit, D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing : October 22, 2024 Date Of Pronouncing The Order : November 19, 2024 O R D E R

Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 144Section 250Section 56(2)(vii)Section 69A

issued as per three formats that are: (i)Limited Scrutiny (Computer Aided Scrutiny System) (ii)Complete Scrutiny (Computer Aided Scrutiny System) (iii)Compulsory Manual Scrutiny The CBDT has also provided the formats as under: 4 Srimanta Kumar Shit (i)Limited Scrutiny(Computer Aided Scrutiny System) “Limited Scrutiny (Computer Aided Scrutiny ... Selection) Notice under section 143(2) of the Income Tax Act, 1961” (ii)Complete Scrutiny (Computer Aided Scrutiny System) “Complete Scrutiny (Computer Aided Scrutiny Selection) Notice under section 143(2) of the Income Tax Act, 1961” (iii)Compulsory Manual Scrutiny “Compulsory Manual Selection Notice under section

Veena Rani (Legal Heir of Late Sh. Mahender Pal Narang), Fatehabad vs. Pr, CIT, Rohtak

In the result, the Appeal filed by the Assessee stands allowed

ITA 1504/DEL/2023[2018-19]Status: DisposedITAT Delhi19 Nov 2024AY 2018-19

Bench: Shri Shamim Yahya & Shri Vimal Kumara.Yr. : 2018-19 Veena Rani, Vs. Principal Commissioner (Legal Heir Of Late Sh. Of Income Tax, Mahender Pal Narang), Rohtak, House No. 221, Ward No. 9, Aayakar Bhawan, Shiv Chowk, Near Op. Mansarover Park, Gurdwara, Faridabad, Rohtak, Haryana-124001 Haryana-125050 (Pan: Alzpr5949K) (Appellant) (Respondent)

For Appellant: Sh. Salil Kapoor, Adv. & Sh. AnilFor Respondent: Shri Sanjay Pandey, CIT(DR)
Section 143(1)Section 143(3)Section 263Section 28

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “H”, NEW DELHI BEFORE SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER, AND SHRI VIMAL

Nawal Kishore Rajgarhia, Kolkata vs. D.C.I.T., Circle - 3(1), Kolkata

The appeal of the assessee is partly allowed as indicated above

ITA 1884/KOL/2024[2015-2016]Status: DisposedITAT Kolkata18 Nov 2024AY 2015-2016

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmai.T.A. No.1884/Kol/2024 Assessment Year: 2015-16 Nawal Kishore Rajgarhia…………………………………………….…..……Appellant C/O Subash Agarwal & Associates, Advocates, Siddha Gibson, 1, Gibson Lane, Suite 213, 2Nd Floor, Kolkata – 700069. [Pan: Acqpr3401G] Vs. Dcit, Circle-3(1), Kolkata............…..….…..….........……........……...…..…..Respondent Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri Pradip Biswas, Addl. Cit- Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 30, 2024 Date Of Pronouncing The Order : November 18, 2024 Order Per Sonjoy Sarma: The Present Appeal Is Filed By The Assessee Against The Order Dated 31.07.2023 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. The Assessee Filed His Return Of Income On 14.08.2015 Declaring A Total Income Of Rs.38,62,700/-. The Return Was Selected For Limited Scrutiny On Two Specific Issues: I. Gross Interest Shown In Schedule Os Of Itr Is Less Than Interest Receipt Reported In 26As. Ii. Large Value Sale Of Option In Securities (Derivative) In A Recognized Stock Exchange & No Business Income Declared By The Assessee (Stt Code-4)

Section 143(2)Section 250Section 68

that the assessment in the case of the assessee was selected for limited scrutiny on specific grounds and without converting the limited scrutiny to complete scrutiny, the Assessing Officer had no authority to examine these issues viz. sale proceeds on shares and claim of long-term capital loss outside ... exceeds the scope of limited scrutiny. As per the Income Tax guidelines, a limited scrutiny case cannot be exceeded without proper conversion to complete scrutiny. The Assessing Officer was not justified in making addition or disallowance on the issues as the Assessing Officer was not supposed to examine any other

Kco Aluminium LLP, Kolkata vs. PCIT - 2, Kolkata

The appeals are dismissed

ITA 1137/KOL/2024[2018-2019]Status: DisposedITAT Kolkata18 Nov 2024AY 2018-2019

Bench: SHRI RAJPAL YADAV, VICE PRESIDENT SHRI SANJAY AWASTHI (Accountant Member)

Section 142(1)Section 143(3)Section 263

case, the Scrutiny u/s 143(3) of the Act for the Assessment year 2018-19 was Limited Scrutiny which was NOT enhanced to Complete Scrutiny by the Ld.AO with the permission of the Principal Commissioner of Income Tax ((herein after referred as "Ld. PCIT"). 3. That on the facts