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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

Late Muthumalainadar Krishnavel, Represented by 6 Legal Heirs, Tuticorin vs. PCIT-1, Madurai

The appeal stand allowed in terms of our above order

ITA 1018/CHNY/2024[2016-17]Status: DisposedITAT Chennai18 Nov 2024AY 2016-17

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1018/Chny/2024 (िनधा"रण वष" / Assessment Year: 2016-17) Smt. K.Indira, Pcit-1 Shri K.Muthuvel, Madurai. Shri Selvakumaran, Shri M.K.Balaji बनाम/ Shri K.Ragupathy, Shri K.Sudhakar Vs. All L/Hs Of Late Shri Muthumalainadar Krishnavel, 15, Melanavaladivillai, Arumuganeri, Tuticorin-628 202. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Bctpk-6952-M (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri S.Sridhar (Advocate)-Ld. Ar ""थ"कीओरसे/Respondent By : Shri R.Clement Ramesh Kumar (Cit)-Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 29-08-2024 घोषणाकीतारीख /Date Of Pronouncement : 18-11-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri S.Sridhar (Advocate)-Ld. ARFor Respondent: Shri R.Clement Ramesh Kumar (CIT)-Ld. DR
Section 143(3)Section 147Section 263Section 56Section 56(2)(vii)

subsequent reduction in the circle rates, there by vitiating the findings in relation there to. 11. The PCIT failed to appreciate that there was complete scrutiny of facts referred to in the revision order while passing the re-assessment order passed by the JAO and hence ought to have appreciated

Tpl- Sucg Consortium, Hyderabad vs. Income Tax Officer, Circle 6(3), Hyderabad

In the result, the appeal of assessee is allowed

ITA 753/HYD/2024[2018-19]Status: DisposedITAT Hyderabad14 Nov 2024AY 2018-19

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

For Appellant: Shri Malay Kalavadia, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 142(1)Section 143(2)Section 80Section 80I

filed its return of income declaring total income of Rs.7,65,80,020/- for AY 2018-19 on 28/11/2018. The case was selected for complete scrutiny to examine expenditure of personal nature, refund claim, deduction claimed for Industrial Undertaking. Notice u/s 143(2) of the Act was issued

Sanjay Diwakarrao Vaidya, Aurangabad vs. Income Tax Officer Ward 3(2), Aurangabad

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

ITA 2037/PUN/2024[2015-2016]Status: DisposedITAT Pune11 Nov 2024AY 2015-2016

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2037/Pun/2024 "नधा"रण वष" / Assessment Year : 2015-16

For Appellant: NoneFor Respondent: Shri Arvind Desai
Section 10(37)Section 133(6)Section 143(1)Section 143(2)Section 143(3)Section 250

income on 01.04.2016 disclosing total income at Rs.1,60,630/-. Return was processed u/s.143(1) of the Act. Subsequently, the case was selected for complete scrutiny under Computer Assisted Scrutiny Selection (CASS). Statutory Notices u/s.143(2) and 142(1) of the Act were issued to the assessee

Agrawal Rajeshkumar Babulal, HUF, Banaskantha vs. The ACIT, Circle Palanpur Present Jurisdiction the ACIT, Circle- Gandhinagar, Gandhinagar

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

ITA 871/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad08 Nov 2024AY 2017-18

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

For Appellant: Shri Rignesh Das, Sr. DRFor Respondent: Date of Hearing
Section 143(3)Section 37

HUFvs.ACIT] A.Y. 2017-18- 2 – return of income for A.Y. 2017-18 was filed on 07.07.2018 declaring Nil income. The case was selected for complete scrutiny under CASS. The assessment was completed under Section 143(3) of the Income Tax Act, 1961 (in short ‘the Act’) on 31.12.2019 at total

Sree Narayana Dharma Sabha, Kodungallur-Thrissur vs. Income Tax Officer(Exemption), Thrissur

In the result, the appeals filed by the assessee are allowed

ITA 154/COCH/2024[2018-19]Status: DisposedITAT Cochin08 Nov 2024AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Sri.P.J.Anil Kumar, AdvocaateFor Respondent: Smt.Girly Albert, Sr.DR
Section 11Section 143(1)Section 2(15)

income was applied for the charitable purposes. Thereafter, the return was processed u/s.143(1) of the Act and the case was selected for complete scrutiny assessment for which various details were called for by the Assessing Officer. The assessee also filed all the details sought for by the A.O. along

Sree Narayana Dharma Sabha, Kodungallur-Thrissur vs. Income Tax Officer(Exemption), Thrissur

In the result, the appeals filed by the assessee are allowed

ITA 153/COCH/2024[2016-17]Status: DisposedITAT Cochin08 Nov 2024AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Sri.P.J.Anil Kumar, AdvocaateFor Respondent: Smt.Girly Albert, Sr.DR
Section 11Section 143(1)Section 2(15)

income was applied for the charitable purposes. Thereafter, the return was processed u/s.143(1) of the Act and the case was selected for complete scrutiny assessment for which various details were called for by the Assessing Officer. The assessee also filed all the details sought for by the A.O. along

Sree Narayana Dharma Sabha, Kodungallur-Thrissur vs. Income Tax Officer(Exemption), Thrissur

In the result, the appeals filed by the assessee are allowed

ITA 152/COCH/2024[2015-16]Status: DisposedITAT Cochin08 Nov 2024AY 2015-16

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Sri.P.J.Anil Kumar, AdvocaateFor Respondent: Smt.Girly Albert, Sr.DR
Section 11Section 143(1)Section 2(15)

income was applied for the charitable purposes. Thereafter, the return was processed u/s.143(1) of the Act and the case was selected for complete scrutiny assessment for which various details were called for by the Assessing Officer. The assessee also filed all the details sought for by the A.O. along

Sree Narayana Dharma Sabha, Kodungallur-Thrissur vs. Income Tax Officer(Exemption), Thrissur

In the result, the appeals filed by the assessee are allowed

ITA 151/COCH/2024[2013-14]Status: DisposedITAT Cochin08 Nov 2024AY 2013-14

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Sri.P.J.Anil Kumar, AdvocaateFor Respondent: Smt.Girly Albert, Sr.DR
Section 11Section 143(1)Section 2(15)

income was applied for the charitable purposes. Thereafter, the return was processed u/s.143(1) of the Act and the case was selected for complete scrutiny assessment for which various details were called for by the Assessing Officer. The assessee also filed all the details sought for by the A.O. along

Sree Narayana Dharma Sabha, Kodungallur-Thrissur vs. Income Tax Officer(Exemption), Thrissur

In the result, the appeals filed by the assessee are allowed

ITA 150/COCH/2024[2012-13]Status: DisposedITAT Cochin08 Nov 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Sri.P.J.Anil Kumar, AdvocaateFor Respondent: Smt.Girly Albert, Sr.DR
Section 11Section 143(1)Section 2(15)

income was applied for the charitable purposes. Thereafter, the return was processed u/s.143(1) of the Act and the case was selected for complete scrutiny assessment for which various details were called for by the Assessing Officer. The assessee also filed all the details sought for by the A.O. along

Mma Offshore Asia Vessel Operations Pte Ltd., Singapore vs. CIT (International Taxation)-3, Mumbai

ITA 2567/MUM/2024[2020-21]Status: DisposedITAT Mumbai08 Nov 2024AY 2020-21

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Sunil Kumar Singh, Hon'Ble

For Appellant: Shri Nitesh Joshi/Punit Lohiya, A/RsFor Respondent: Shri Vivek Perampurna, D/R
Section 142(1)Section 195Section 263

mutandis the same. 6. The assessee filed its return of income on 26/09/2019 declaring total income of Rs. Nil. The return was selected for complete scrutiny through CASS with following reasons:- a) The assessee has claimed substantial refund out of TDS u/s 195. b) The assessee has claimed substantial amount

Mma Offshore Asia Vessel Operations Pte Ltd., Singapore vs. CIT (International Taxation)-3, Mumbai

ITA 2566/MUM/2024[2019-20]Status: DisposedITAT Mumbai08 Nov 2024AY 2019-20

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Sunil Kumar Singh, Hon'Ble

For Appellant: Shri Nitesh Joshi/Punit Lohiya, A/RsFor Respondent: Shri Vivek Perampurna, D/R
Section 142(1)Section 195Section 263

mutandis the same. 6. The assessee filed its return of income on 26/09/2019 declaring total income of Rs. Nil. The return was selected for complete scrutiny through CASS with following reasons:- a) The assessee has claimed substantial refund out of TDS u/s 195. b) The assessee has claimed substantial amount ... mutandis the same. 6. The assessee filed its return of income on 26/09/2019 declaring total income of Rs. Nil. The return was selected for complete scrutiny through CASS with following reasons:- a) The assessee has claimed substantial refund out of TDS u/s 195. b) The assessee has claimed substantial amount

Assistant Commissioner of Income Tax, Circle 4(2)(1), Mumbai vs. Euro Pratik Ispat India Private Limited, Andheri East, Mumbai

In the result, appeal of the revenue is dismissed

ITA 3961/MUM/2024[2020-21]Status: DisposedITAT Mumbai06 Nov 2024AY 2020-21

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Sandeep Singh Karhail, Hon’Ble

For Appellant: Shri R.B. Doshi, A/RFor Respondent: Shri Biswanath Das, CIT, D/R
Section 133(6)Section 68

that the assessee filed its return of income on 31/12/2020 declaring total income of Rs.47,08,25,890/-. The return was selected for complete scrutiny on account of large difference in the opening stock of current year and closing stock of previous year. The statutory notices were accordingly issued

Tamura Elcomponics Technologies Private Limited, Uttar Pradesh vs. National E-Assessment Center, Delhi, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1291/DEL/2024[A.Y. 2018-19]Status: DisposedITAT Delhi06 Nov 2024

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR KUMAR (Judicial Member)

For Appellant: Shri Shivansh Bansal, CAFor Respondent: Shri B.S. Anand, Sr. DR
Section 143Section 250(6)Section 37

case are, assessee filed its return of income for Assessment Year 2018-19 declaring total income at Rs.Nil. The case was selected for 2 complete scrutiny under e-assessment scheme 2019 to verify the issue of business loss and business expenses. Accordingly, notices

Maharani Wines, Nashik vs. ACIT Circle 1, Nashik

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

ITA 1511/PUN/2024[2018-19]Status: DisposedITAT Pune05 Nov 2024AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19

For Appellant: Shri Sanket M JoshiFor Respondent: Shri Amol Khairnar, CIT-DR
Section 115BSection 133(6)Section 143(2)Section 69C

government. It filed its return of income on 05.10.2018 declaring total income of Rs.9,62,170/-. The case of the assessee was selected for complete scrutiny under the E-assessment Scheme, 2019 on the following issue: “The assessee has disclosed low income from receipts (liquor) on which TCS has been

M/S. Varda Estate and Properties Pvt. Ltd., Lucknow vs. Deputy Commissioner of Income Tax, Range-6, Lucknow

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

ITA 109/LKW/2020[2015-16]Status: DisposedITAT Lucknow29 Oct 2024AY 2015-16

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2015-16 M/S Varda Estate & Tax V. The Dy. Cit Properties Pvt. Ltd Range - 6, 8, Jagdish Chanda Bose Marg Lucknow Lalbagh, Lucknow Tan/Pan:Aaecv0063D (Appellant) (Respondent)

For Appellant: Shri Kumar Saurav, C.AFor Respondent: Shri S. B.Usmani, CIT(DR)
Section 142(1)Section 143Section 143(2)Section 144

Rs.28,83,000/- in his bank account, but the revenue from the same was shown at Nil. Subsequently, the case was selected for complete scrutiny. Since the Assessee had not complied with the notices issued by the AO, he completed the assessment under section 144 of the Act, assessing

Geeta Sharma, Sunam vs. Principal Commissioner of Income Tax, Patiala

ITA 476/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh29 Oct 2024AY 2019-20

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

For Appellant: Shri Rajiv Saldi, CAFor Respondent: ShriRohit Sharma, CIT DR
Section 10(37)Section 142(1)Section 143(2)Section 253Section 263Section 44ASection 80T

income of Rs.14,65,910.00 for assessment year 2019-20 vide acknowledgement number 501367120120619 on 12.06.2019. The case of the assessee was selected for complete scrutiny under CASS for the following reasons:- (1) Issue of Refund Claim: 3. That a notice under Section 143(2) of the Income ... www.Incometaxindiaefiling.gov.in) within 15 days from the date of receipt of the notice. 4. That the assessee was specifically advised that since it is a complete scrutiny proceedings, he should gather all the information, documents, evidences, etc. related to the above referred issues and in respect of various financial transactions entered

Gujarat Tea Processors & Packers Ltd., Ahmedabad vs. The Pr. CIT-1, Ahmedabad

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

ITA 837/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad29 Oct 2024AY 2018-19

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita No. 837/Ahd/2024 "नधा"रण वष"/Asstt. Year: 2018-2019 Gujarat Tea Processor & Packers Principal Ltd., बनामVs Commissioner Of . Waghbakri House, Income Tax-1, Opp. Parimal Garden, Ahmedabad. Ellisbridge, Ahmedabad-380006. Pan: Aaacg5594L ( ""यथ" /Respondent) (अपीलाथ" /Appellant Assessee By : Shri Yogesh Shah, Ar Revenue By : Shri R.N Dsouza, Cit.Dr सुनवाई क" तार"ख/Date Of Hearing : 30/09/2024 घोषणा क" तार"ख /Date Of Pronouncement: 29/10/2024 आदेश/O R D E R Per Narendra Prasad Sinha, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Pcit, Ahmedabad-1, Dated 29.02.2023 For The Assessment Year (A.Y.) 2018- 19, Passed In His Revisional Jurisdiction U/S. 263 Of The Income Tax Act (Hereinafter Referred To As “The Act”).

For Appellant: Shri Yogesh Shah, ARFor Respondent: Shri R.N Dsouza, CIT.DR
Section 143(3)Section 14ASection 263

filed by the assessee on 23.10.2018, declaring total income of Rs.1,40,71,94,040/-. The case was selected for complete scrutiny and the Asst. Year 2018-19 2 assessment was completed u/s. 143(3) of the Act on 12.04.2021 at total income of Rs.1,40,71,95,040/-. Subsequently ... Asst. Year 2018-19 4 6. We have considered the rival submissions. It is found that the case of the assessee was selected for complete scrutiny. The fact that the assessee had made investment in equity shares during the year and the income earned thereon was exempt from

DCIT, Pune vs. Bajaj Allianz Life Insurance Company Limited, Pune

In the result, both the appeals filed by the Revenue are dismissed

ITA 654/PUN/2024[2018-19]Status: DisposedITAT Pune29 Oct 2024AY 2018-19

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

For Appellant: Shri Percy Pardiwalla &For Respondent: Shri P R Mane
Section 10(15)Section 10(34)Section 143(1)Section 143(2)Section 14ASection 44

Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) accepting the returned income. Subsequently, the case was selected for complete scrutiny under CASS. Accordingly, statutory notices u/s 143(2) and 142(1) of the Act were issued and served on the assessee, in response to which the assessee filed

DCIT, Pune vs. Bajaj Allianz Life Insurance Company Limited, Pune

In the result, both the appeals filed by the Revenue are dismissed

ITA 653/PUN/2024[2016-17]Status: DisposedITAT Pune29 Oct 2024AY 2016-17

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

For Appellant: Shri Percy Pardiwalla &For Respondent: Shri P R Mane
Section 10(15)Section 10(34)Section 143(1)Section 143(2)Section 14ASection 44

Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) accepting the returned income. Subsequently, the case was selected for complete scrutiny under CASS. Accordingly, statutory notices u/s 143(2) and 142(1) of the Act were issued and served on the assessee, in response to which the assessee filed

Chandraprabhu Gramin Bigar Sheti Sahakari Pat Sanstha, Solapur vs. Income Tax Officer, Ward-2, Pandharpur

In the result, the appeal of the assessee is allowed

ITA 1858/PUN/2024[2018-19]Status: DisposedITAT Pune29 Oct 2024AY 2018-19

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

For Appellant: Shri Sharad ShahFor Respondent: Shri B.S. Rajpurohit
Section 143(2)Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

assessee filed its return of income electronically on 30.10.2018 declaring total income at Rs. Nil. Subsequently, the case was selected for a complete scrutiny under the E-assessment Scheme, 2019 on the following two issues-(i) Investments/Advances/Loans; and (ii) Deduction from total income under Chapter VI-A. Statutory notice