“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

Just Dial Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 4(3)(1), Mumbai

In the result, the appeal by the Revenue for the assessment year 2020-

ITA 254/MUM/2024[2017-18]Status: DisposedITAT Mumbai23 Sept 2024AY 2017-18

Bench: Shri. Om Prakash Kant & Shri. Sandeep Singh Karhail

For Appellant: Shri Madhur Agarwal, Ms. MokshaFor Respondent: Shri Ankush Kapoor, CIT DR

Section 115Section 115JSection 250

Just Dial Ltd income of ₹ 9,93,21,750. The return filed by the assessee was selected for complete scrutiny through CASS and statutory notices under section 143(2) and section 142(1) of the Act were issued and served on the assessee. During the year under consideration, the assessee

Haldex Anand India Private Limited, Nashik vs. National Faceless Assessment Centre, Delhi

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

ITA 638/PUN/2024[2018-19]Status: DisposedITAT Pune20 Sept 2024AY 2018-19

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

For Appellant: Shri R.D. OnkarFor Respondent: Shri Ramnath P. Murkunde

Section 115PSection 143Section 143(1)Section 143(2)Section 143(3)Section 144BSection 40A(2)(b)

Income Tax Act, 1961 (the “Act”) determining total income at Rs.10,10,40,930/-. Thereafter, the case was selected for complete scrutiny under CASS for verification of-(i) claim of any other amount allowable as deduction in schedule BP; (ii) refund claim and (iii) transaction with company whose registration

ACIT 14(I)(2), Mumbai vs. Godrej Properties Limited, Mumbai

ITA 3880/MUM/2024[2017-18]Status: DisposedITAT Mumbai20 Sept 2024AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri Gagan Goyal1. Ita No. 3880/Mum/2024 (A.Y.2017-18)

For Appellant: Shri P. Suresh, Ld. DRFor Respondent: Shri Jeet Kamdar, Ld. AR

Section 14ASection 250

return of income was revised on 03.01.2019 claiming the same amount of loss. The return of the assessee was selected for complete scrutiny under CASS and relevant notices were issued. Ultimately, case of the assessee was assessed by making various additions /disallowances under the head ‘Income from House Property

Paradise Infrastructure, Jaipur vs. Assistant Commissioner of Income Tax, Circle-1, Jaipur

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

ITA 871/JPR/2024[2017-18]Status: DisposedITAT Jaipur19 Sept 2024AY 2017-18

Bench: The Learned Ao.

For Appellant: Shri S.L. Poddar (Adv.)For Respondent: Shri Anup Singh (Addl. CIT)

Section 142(1)Section 143(2)Section 143(3)Section 40

engaged in the business of construction & developer and earned income from business or profession. The case was selected for scrutiny assessment through CASS under "Complete Scrutiny and notice u/s 143(2) of the Act, was issued on 13.08.2018 through ITBA-portal which was duly served upon the assessee. During

Gandhar Oil Refinery (India) Limited, Mumbai vs. CC 5(1), Mumbai

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

ITA 3889/MUM/2024[2016-17]Status: DisposedITAT Mumbai19 Sept 2024AY 2016-17

Bench: Shri Pavan Kumar Gadale & Shri Gagan Goyalgandharoilrefinery(India)Ltd., Acit, Cc-5(1), Vs. 18Th Floor, Dlh Park, Sv Air India Building Road, Goregaon (West), Mumbai-400021. Mumbai-400062.. Pan/Gir No. Aaacg3996J (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 143(1)Section 2(24)(x)Section 35Section 36(2)

Rs.12,27,87,970/- and the return of income was processed u/s 143(1) of the Act. Subsequently the case was selected for complete scrutiny under CASS and notice u/sec 143(2) and u/sec 142(1)of the Act are issued. Since the assesse has specific domestic transactions

Income Tax Officer, Ward-1(1), Nashik vs. Mico Employees Credit Coop Society Ltd., Nashik

In the result, the appeal of the Revenue is dismissed

ITA 281/PUN/2024[2017-18]Status: DisposedITAT Pune18 Sept 2024AY 2017-18

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

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Ramnath P. Murkunde

Section 143(2)Section 56Section 80(2)(d)Section 80PSection 80P(2)(a)

assessee filed its return of income for AY 2017-18 on 29.10.2017 declaring total income of Rs.3,74,320/-. The case was selected for complete scrutiny under CASS and statutory notice(s) u/s 143(2)/142(1) of the Income Tax Act, 1961 (the “Act”) were issued calling for various

Adarsh Gramin Bigar Sheti Sahakari Patsanstha Limited, Ahmednagar vs. Commissioner of Income Tax (A), Pune

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

ITA 1536/PUN/2024[2018-19]Status: DisposedITAT Pune18 Sept 2024AY 2018-19

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.1536/Pun/2024 "नधा"रण वष" / Assessment Year : 2018-19

For Appellant: Shri Devendra A. PaatilFor Respondent: Shri B.S. Rajpurohit

Section 143(3)Section 80P(2)(a)

claiming exemption u/s 80P(2)(a)(i) of the Income Tax Act, 1961 (‘the Act’) of Rs.26,06,783/-. The case was selected for complete scrutiny for verification of (i) Investments/Advances/Loans; (ii) Excess Contribution to Provident 2 Fund, Superannuation Fund or Gratuity Fund; and (iii) Deduction from Total Income under

Kolhapur District Chemist Co Op Credit Society Limited, Kolhapur vs. Dy. CIT Circle 1, Kolhapur

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

ITA 1517/PUN/2024[2020-2021]Status: DisposedITAT Pune18 Sept 2024AY 2020-2021

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.1517/Pun/2024 "नधा"रण वष" / Assessment Year : 2020-21 Kolhapur District Chemist Coop. Vs. Dcit, Circle-1, Credit Society Limited, Kolhapur 451, E-Ward, Chemist Bhavan, Kevis Plaza, Kolhapur – 416 001 Maharashtra Pan : Aabak1663K Appellant Respondent

For Appellant: Shri Mayuresh DoshiFor Respondent: Shri B.S. Rajpurohit

Section 143(3)Section 80P(2)(a)

Rs.64,18,521/- u/s.80P(2)(a)(i) of the Income Tax Act, 1961 (‘hereinafter also called ‘the Act’). The case was selected for complete scrutiny through CASS for verification of (i)Investments/ Advances/Loans, (ii) High Creditors/Liabilities, and (3) Deduction from total income under Chapter VI-A. Against the said return

Shri Swami Vivekanand Shikshan Sansthechya Sevakanchi Sahakari Patsanstha, Kolhapur vs. Income Tax Officer, Kolhapur

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

ITA 1484/PUN/2024[2017-18]Status: DisposedITAT Pune18 Sept 2024AY 2017-18

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.1484/Pun/2024 "नधा"रण वष" / Assessment Year : 2017-18

For Appellant: Shri Pramod ShingteFor Respondent: Shri B.S. Rajpurohit

Section 143(3)Section 80P(2)(a)

claiming exemption u/s 80P(2)(a)(i) of the Income Tax Act, 1961 (‘the Act’) of Rs.10,25,271/-. The case was selected for complete scrutiny through CASS for verification of (i) the deduction claimed under 2 Chapter VI-A and (ii) investments/advances/loans. Against the said return of income

Ans Jewellery, Salem vs. DCIT, Non Corporate Circle-1(1), Salem

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

ITA 161/CHNY/2024[2021-22]Status: DisposedITAT Chennai18 Sept 2024AY 2021-22

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita Nos.160 & 161/Chny/2024 िनधा"रण वष"/Assessment Year: 2020-21 & 2021-22 V. M/S.Ans Jewelry, The Dcit, 284, Omalur Main Road, Non-Corporate Circle-19(1), Swarnapuri, Salem. Salem-636 004. [Pan: Aahfa 8980 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Ms. R. Anita, Addl.CIT

Section 270ASection 40A(2)(b)

return of income (RoI) on 16.09.2020 for AY 2020- 21 declaring total taxable income at Rs.95,23,430/-. Later, the case was selected for complete scrutiny and the AO noted that the assessee has claimed business expenditure viz. interest payment made to unsecured creditors (related parties) @21% of the total

Ans Jewelry, Salem vs. DCIT, Non Corporate Circle-19(1), Salem

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

ITA 160/CHNY/2024[2020-21]Status: DisposedITAT Chennai18 Sept 2024AY 2020-21

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Ms. R. Anita, Addl.CIT

Section 270ASection 40A(2)(b)

Shree Mangal Ram Roller Flour Mills, Ambala vs. Income Tax Officer, Ward-4, Ambala

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

ITA 127/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh13 Sept 2024AY 2017-18

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

For Appellant: Shri Dhruv Goel, C.AFor Respondent: Shri Vivek Nangia, CIT DR

Section 143(2)

return declaring taxable income of Rs. 2,61,810/- for the A.Y. 2017-18 on 30/10/2017. Later on, the case was selected for complete scrutiny under CASS. Thereafter, notice under section 143(2) of the Act was issued on 06/09/2018 and served upon the assessee electronically. The AO stated that

Mohit Furnace Private Limited, Ludhiana vs. Assessment Unit, Faceless

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

ITA 746/CHANDI/2023[2021-22]Status: DisposedITAT Chandigarh13 Sept 2024AY 2021-22

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

For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Smt, Kusum Bansal, CIT DR

Section 143(2)Section 144Section 250Section 253Section 68Section 69C

income on 15/03/2022 for the A.Y. 2021-22, declaring total income of Rs. NIL/-. Subsequently, the case was selected under CASS under category 'Complete scrutiny.' Accordingly notice u/s 143(2) of the I T Act & other notices were issued and the assessment was completed u/s 144 r.w.s 144B

Vikas Sabharwal HUF, Ludhiana vs. Income Tax Officer, Ludhiana

In the result appeal of the assessee is allowed in terms as aforesaid

ITA 740/CHANDI/2023[2017-2018]Status: DisposedITAT Chandigarh13 Sept 2024AY 2017-2018

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

For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Shri Vivek Vardhan, JCIT, Sr. DR

Section 115BSection 142(1)Section 143(2)Section 253Section 69A

filed its return of income on 05.08.2017 declaring total income of Rs.2,18,980/- vide acknowledgement No.150870440050817. Thereafter, the case was selected for complete scrutiny under CASS on the main reason "cash deposits during demonetization period and gross total income including exempt income and agricultural income". Notice under section

Ace Urban Developers Private Limited, Hyderabad vs. AO, Vijayawada

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

ITA 79/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam13 Sept 2024AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.Nos.79, 118 & 284/Viz/2024 (निर्धारणवर्ा/ Assessment Year: 2016-17, 2018-19 & 2016-17) Ace Urban Developers Private Limited V. The Asst. Cit- Circle-2(1) Module No. A1, A2,A3 Vijayawada – 520002 Quadrant No. 4, 4Thfloor Andhra Pradesh Cyber Tower, Hitech City Madhapur B.O. Sheikpet, Hyderabad-500081, Telangana [Pan: Aanca4001H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Sk Gupta,Ar राजस्व का प्रतततितित्व / Department Represented By : Dr. Satyasai Rath, Sr.Ar

Section 143(3)Section 263Section 68

Return of Income for the impugned Assessment Year on 17.10.2016 admitting total loss at Rs.1,48,76,020/-. The case was selected for complete scrutiny. Assessing Officer completed the assessment under section 143(3) of the Act on 26.12.2018after making following additions: - a. Unsecured loan amounting Rs. 3 Crores ... cities filed its return of income for the A.Y.2018-19 on 28.11.2018 admitting loss of Rs. 11,32,51,419/-. The case was selected for complete scrutiny and Statutory notices under section 143(2) and 142(1) of the Act were issued on various dates. In response, assessee filed various details

Ace Urban Developers Private Limited, Hyderabad vs. Assistant Commissioner of Income Tax, Circle-2(1), Vijayawada

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

ITA 284/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam13 Sept 2024AY 2016-17

Section 143(3)Section 263Section 68

Ace Urban Developers Private Limited, Hyderabad vs. AO, NFAC

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

ITA 118/VIZ/2024[2018-19]Status: DisposedITAT Visakhapatnam13 Sept 2024AY 2018-19

Section 143(3)Section 263Section 68

Kiran Kumar Singh, Howrah vs. I.T.O., Ward - 47(6), Kolkata

In the result, appeal of the assessee is allowed

ITA 1335/KOL/2024[2017-2018]Status: DisposedITAT Kolkata13 Sept 2024AY 2017-2018

Bench: Shri Sonjoy Sarma (Judicial Member), Shri Rakesh Mishra (Accountant Member)

Section 144Section 250Section 69A

income for the AY 2017-18 by disclosed total income amounting to Rs. 7,99,870/-. The case of the assessee was selected for complete scrutiny under CASS in order to verify the cash deposit made during the demonetization period as the assessee made cash deposit

Mohan Singh, Vidhyadhar Nagar vs. Income Tax Officer, Ncrb Jaipur

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

ITA 191/JPR/2024[2018-19]Status: DisposedITAT Jaipur13 Sept 2024AY 2018-19

For Appellant: Shri S.K. Gogra (C.A.)For Respondent: Shri Arvind Kumar (CIT)

Section 142(1)Section 143(2)Section 143(3)Section 144BSection 234A

return of income for AY 2018-19 electronically on 10.10.2018 declaring total income of Rs. 10,38,940/-. The assessee case was selected for complete scrutiny under CASS and notice u/s 143(2) dated 22/09/2019 was issued, calling it to produce certain details/explanations/materials on which relied or support

Shubhmultitrade Private Limited, Mumbai vs. ITO Ward-11(2)(1), Mumbai

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

ITA 2881/MUM/2024[2020-21]Status: DisposedITAT Mumbai11 Sept 2024AY 2020-21

Bench: Shri. Prashant Maharshi & Shri. Sandeep Singh Karhail

For Appellant: Shri. NoneFor Respondent: Shri. Akhatar Hussain Ansari, Sr. DR

Section 131Section 132Section 142(1)Section 143(2)Section 144Section 144BSection 250

assessee filed its return of income on 06/01/2021 declaring a total income of Rs.2730. The return filed by the assessee was selected for complete scrutiny and statutory notices under section 143(2) as well as section 142(1) of the Act were issued and served on the assessee. However