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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

Shilpkars Clothing Co., Mumbai vs. The Pr. CIT - 27, Mumbai

ITA 2859/MUM/2024[2018-19]Status: DisposedITAT Mumbai11 Sept 2024AY 2018-19

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Rahul Chaudhary, Hon’Ble

For Appellant: Shri Dharmesh Shah a/w Ms. Mitali ParekhFor Respondent: Shri S. Srinivasu
Section 115BSection 144Section 263Section 37(1)Section 68Section 69A

ITAT Rules. 4. Briefly stated facts of the case are that the return of income of the assessee was selected for complete scrutiny assessment under the e- assessment scheme 2019 on the following issues:- (i) Investments / advances / loans (ii) Business loss and (iii) Unsecured loans 5. The assessment order framed

Sh. Karam Chand, Mansa vs. Pr.CIT (Central), Ludhiana

In the result, the appeal of the assessee is allowed

ITA 341/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh10 Sept 2024AY 2018-19

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Amanpreet Kaur, Sr. DR
Section 115BSection 143(2)Section 143(3)Section 263Section 69B

this regard, our reference was drawn to the assessment order wherein the AO has stated that the case of the assessee was selected for complete scrutiny being a survey case and thereafter he has issued notices and detailed questionnaire and in response to these notices, the assessee has furnished requisite

Ch Rama Rao, Vijayawada vs. Income Tax Officer, Ward-3(4), Vijayawada

In the result, appeal of the assessee is partly allowed for statistical purposes as indicated herein above

ITA 153/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam10 Sept 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.153/Viz/2024 (िनधा"रण वष" / Assessment Year : 2017-18) Ch. Rama Rao, Vs. Income Tax Officer, 4-99, Ramavarappadu, Ward-3(4), Vijayawada-521108. Vijayawada. Pan: Aacfc0545L (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri C. Subrahmanyam, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar सुनवाई क" तारीख / Date Of Hearing : 18/07/2024 घोषणा क" तारीख/Date Of : 10/09/2024 Pronouncement O R D E R

For Appellant: Sri C. Subrahmanyam, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 142(1)Section 143(2)Section 143(3)Section 40Section 40A(2)Section 44A

submitted the audit report as per the provisions of section 44AB of the Act. Subsequently, the case of the assessee was selected for “complete scrutiny” under CASS to examine the ‘large value cash deposits during the demonetization period’. Accordingly, statutory notice U/s. 143(2) of the Act was issued through ... other hand, Ld. DR strongly objected to the argument of the Ld. AO and submitted that the case was selected for complete scrutiny and it is not reopened for limited scrutiny and the same was also mentioned in the assessment order passed by the Ld. AO. Therefore, the assessment order

Chandrasekhar Yernena, Visakhapatnam vs. Income Tax Officer, Ward-4(1), Visakhapatnam

In the result, appeal of the assessee is partly allowed as indicated herein above

ITA 125/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam10 Sept 2024AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.125/Viz/2024 (िनधा"रण वष" / Assessment Year : 2016-17) Chandrasekhar Yernena, Vs. Income Tax Officer, 39-31-68, Gandhi Nagar, Ward-4(1), Marripalem, Visakhapatnam. Visakhapatnam-530018, Andhra Pradesh. Pan: Abqpy2029N (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri N.V. Ramana Murthy, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar सुनवाई क" तारीख / Date Of Hearing : 11/06/2024 घोषणा क" तारीख/Date Of : 10/09/2024 Pronouncement O R D E R

For Appellant: Sri N.V. Ramana Murthy, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 142(1)Section 143(2)Section 143(3)Section 250Section 271(1)(c)Section 69

which includes business income, salary income and commission. Later on, the case was selected for scrutiny through CASS under complete scrutiny. Accordingly, notice U/s. 143(2) of the Act was issued on 03/07/2017and in response to the same, the assessee’s Authorized Representative appeared from time to time and filed

Guru Nanak Steel Traders, Yamuna Nagar vs. Income Tax Officer, Ward-5, Yamuna Nagar

In the result, the appeal of the assessee is allowed

ITA 782/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh09 Sept 2024AY 2017-18

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

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Smt. Amanpreet Kaur, Sr. DR
Section 115Section 133(6)Section 143(2)Section 68Section 69A

assessee filed its return of income on 18/12/2017 declaring total income of Rs. 2,67,090/-. The return of income was selected for complete scrutiny through CASS to verify abnormal increase in cash deposit during the demonetization period as compared to pre-demonetization period. Thereafter, notice under section

Adani Green Energy Limited, Ahmedabad vs. The Pr. CIT, Ahmedabad-1, Ahmedabad

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

ITA 1002/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad09 Sept 2024AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.1002/Ahd/2024 "नधा"रण वष" /Assessment Year : 2018-19 Adani Green Energy Limited The Principal Cit Adani Corporate House बनाम/ Ahmedabad-1 Shantigram 15, S.G. Highway V/S. Near Vaishno Devi Circle Khodiyar B.O., Khodiyar Ahmedabad – 382 421 (Gujarat) "थायी लेखा सं./Pan: Aanca 1814 G (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Vartik Chokshi, A.R. Revenue By : Shri H. Phani Raju, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 03/09/2024 घोषणा क" तार"ख /Date Of Pronouncement: 09/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: This Appeal Has Been Preferred By The Assessee Against The Order Passed By The Ld.Principal Commissioner Of Income Tax, Ahmedabad-1 (Hereinafter Referred To As "Pcit") Under Section 263 Of The Income Tax Act, 1961 (Hereinafter Referred To As "The Act"), Dated 16-03-2024, For The Assessment Year (Ay) 2018-19. Adani Green Energy Limited Vs. Pr.Cit Asst. Year : 2018-19

For Appellant: Shri Vartik Chokshi, A.RFor Respondent: Shri H. Phani Raju, CIT-DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 14ASection 263

adjustment of Rs.21,06,716/- on account of late payment of employees’ contribution to National Pension Scheme. Later on, the case was selected for complete scrutiny under CASS by issuing notice u/s 143(2) of the Act dated 22-09-2019 for the scrutiny of following issues: 1. Investments/Advances/Loans

Shri Hiteshkumar Patel, Anand vs. The Pr. CIT-1, Vadodara

In the result, appeal of the assessee is allowed

ITA 173/AHD/2022[2017-18]Status: DisposedITAT Ahmedabad09 Sept 2024AY 2017-18

Bench: Smt. Annapurna Gupta & Ms. Suchitra Kambleassessment Year: 2017-18

Section 142(1)Section 143(2)Section 143(3)Section 263Section 40Section 68

properties. The assessee filed return of income on 07.11.2017 showing current year loss at (-) Rs.46,38,276/-. Subsequently, the case was selected for complete scrutiny and notice under Section 143(2) of the Assessment Year: 2017-18 Page 2 of 5 Income tax Act, 1961 was issued on 09.08.2018. Thereafter

M/S Kiran Sanran Associates, Pune vs. Principal Commissioner of Income Tax (Central), Pune

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

ITA 791/PUN/2024[2018-19]Status: DisposedITAT Pune09 Sept 2024AY 2018-19

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

For Appellant: Shri Naveen RanderFor Respondent: Shri Keyur Patel, CIT-DR
Section 143(3)Section 2Section 263Section 28Section 36(1)(va)Section 43BSection 43C

construction, promoters and builders. It filed its return of income on 17.10.2018 declaring total income at Rs.23,09,450/-. The case was selected under ‘complete scrutiny’ under CASS and accordingly on the basis of various submissions filed by the assessee from time to time, the Assessing Officer 2 completed

Economic Explosives Limited, Nagpur vs. National E Assessment Centre, New Delhi

In the result, appeal for the assessment year 2018–19 filed by the assessee is partly allowed

ITA 242/NAG/2023[2018-19]Status: DisposedITAT Nagpur09 Sept 2024AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mani JainFor Respondent: Shri Kailash C. Kanojiya
Section 139Section 142(1)Section 143(2)

under normal provisions and ` 56,35,18,915, under the normal provisions of Minimum Alternate Tax. 5. The case was selected for complete scrutiny under CASS. Notice under section 143(2) of the Act was issued and served on ITBA. Notice under section 142(1) of the Act was issued

Economic Explosives Limited, Nagpur vs. Assistant Commissioner of Income Tax, Central Circle 1 (2), Nagpur

In the result, appeal for the assessment year 2018–19 filed by the assessee is partly allowed

ITA 177/NAG/2022[2017-18]Status: DisposedITAT Nagpur09 Sept 2024AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mani JainFor Respondent: Shri Kailash C. Kanojiya
Section 139Section 142(1)Section 143(2)

under normal provisions and ` 56,35,18,915, under the normal provisions of Minimum Alternate Tax. 5. The case was selected for complete scrutiny under CASS. Notice under section 143(2) of the Act was issued and served on ITBA. Notice under section 142(1) of the Act was issued

M/S Harish Chandra Baldewa, Howrah vs. I.T.O., Ward-46(2), Kolkata

In the result, appeal of the assessee is partly allowed as per terms indicated above

ITA 366/KOL/2020[2015-16]Status: DisposedITAT Kolkata09 Sept 2024AY 2015-16

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. No.366/Kol/2020 Assessment Year: 2015-16 M/S. Harish Chandra Baldewa ………. Appellant 493/B/17, Vikram Vihar, G.T. Road (South) Shibpur Howrah-711102 (Pan: Alipb4249H) Vs. Income Tax Officer ………… Respondent Ward-46(2), Kolkata. Appearances By: Shri Miraj D. Shah, Ar Appeared For Appellant. Shri Rakesh Kumar Das, Cit, Dr Appeared For Respondent. Date Of Concluding The Hearing : 11.06.2024 Date Of Pronouncing The Order : 09.09.2024 Order Per Dr. Manish Borad: This Appeal Filed At The Instance Of The Assessee Pertaining To The Assessment Year (In Short “Ay”) 2015-16 Is Directed Against The Revisionary Order Passed U/S 263 Of The Income Tax Act, 1961 In Short The “Act”) By Ld. Pr. Commissioner Of Income- Tax-16, Kolkata [In Short Ld. “Cit(A)”] Dated 04.03.2020. 2. Grounds Of Appeal Raised By The Assessee Read As Under:

Section 143(3)Section 263Section 44A

metro CIT charge, monetary limit shall be Rs.10 lakhs requiring substantial verification on any other issue, then the case may be taken up for complete scrutiny with the prior approval of the PCIT/CCIT concerned. The another condition put forth by the CBDT is that such approval thereof accorded ... PCIT in writing after being satisfied about imports of the issues necessitating complete scrutiny in that particular case. Further condition that such cases shall be monitored by the Range Head and procedure indicated in Sub-clauses (a) (b) (c) above no longer be remain pending in such cases, which means

Venkateshwara Wires Pvt. Ltd., Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result, the appeal of the assessee is allowed

ITA 322/JPR/2024[2018-19]Status: DisposedITAT Jaipur09 Sept 2024AY 2018-19

Bench: The Ld. Ao As Well As Before The Ld. Cit(A) As The Documents Submitted Was Only In Support Of Confirmations & Other Documents Already Submitted & No New Documents Were Submitted. 2. The Assessee Craves Your Indulgence To Add Amend Or Alter All Or Any Grounds Of Appeal Before Or At The Time Of Hearing.”

For Appellant: Sh. S. L. Poddar, AdvFor Respondent: Sh. Anoop Singh, Addl. CIT
Section 133(6)Section 142(1)Section 143(3)Section 68Section 801ASection 80I

return of income for the year under consideration declaring total income of Rs. 4,80,41,000/- on 14.09.2018. The case was selected for Complete Scrutiny assessment under the E-assessment Scheme, 2019 on the following issues:-- S. No. Issues i. Unsecured Loans Issues ii. Deduction Claimed for Industrial Undertaking

Sanjiv Prakashan, Jaipur vs. ACIT, Circle-1, Jaipur

ITA 9/JPR/2023[2020-2021]Status: DisposedITAT Jaipur09 Sept 2024AY 2020-2021
For Appellant: Sh. Anil Goyal, CAFor Respondent: Sh. Anoop Singh (Addl.CIT)
Section 139(1)Section 143(1)Section 143(1)(a)Section 2(24)(x)Section 36(1)Section 36(1)(va)Section 43B

IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, “B” JAIPUR BEFORE: SHRI SANDEEP GOSAIN, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM

Comparex India P.Ltd, New Delhi vs. ITO, Circle-4(2), New Delhi

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

ITA 2151/DEL/2022[2018-19]Status: DisposedITAT Delhi09 Sept 2024AY 2018-19

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

For Appellant: Shri Ajit Jain, ARFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(2)Section 143(3)Section 144C(10)Section 144C(13)Section 144C(8)Section 92CSection 92C(3)

assessee filed its return of income for AY 2018-19 declaring total income at Rs.4,53,71,290/-. The case was selected for 2 complete scrutiny under CASS. Accordingly, notices u/s 143(2) & 142(1) of the Act were issued and served on the assessee though e-filing portal

Boopenderdas (Vikash) Sungker As Ex- Director of Red Fort India Real Estate Humayun, Mauritius vs. DCIT, Circle International Taxation3(1)(1), Delhi

The appeal is dismissed

ITA 1866/DEL/2022[2018-19]Status: DisposedITAT Delhi06 Sept 2024AY 2018-19

Bench: Dr. B.R.R. Kumar & Shri Anubhav Sharma

For Appellant: Shri Gaurav Jain, Adv. &For Respondent: Shri Vijay B. Vasanta, CIT-DR
Section 143(1)Section 143(2)Section 143(3)

passed under section 143(1) of the Income Act, 1961 (‘the Act’). 9. The return of income filed by the assessee was selected for complete scrutiny vide notice dated 23.09.2019 under section 143(2) of the Act. 10. Since the specific purpose of making investment in Prestige India was achieved

Neptune Buildcon LLP, Vadodara vs. The Income Tax Officer, Ward-1(2)(2) (Previously Ward-1(2)(3)), Vadodara

In the result, the appeal filed by the Assessee is treated as allowed for statistical purposes

ITA 1177/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad05 Sept 2024AY 2014-15

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.1177/Ahd/2024 "नधा"रण वष" /Assessment Year : 2014-15 Neptune Buildcon Llp The Ito, Ward-1(2)(2) 24/P, Imperia बनाम/ [Previously Ward-1(2)(3)] Madhvnagar 4 Rasta Vadodara-390 007 V/S. Off Old Padra Road Vadodara – 390 020 (Gujarat) "थायी लेखा सं./Pan: Aakfn 6673 J (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Hemant Suthar, Ar Revenue By : Shri Sudhakar Verma, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 02/09/2024 घोषणा क" तार"ख /Date Of Pronouncement: 05/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Shri Hemant Suthar, ARFor Respondent: Shri Sudhakar Verma, Sr.DR
Section 143(2)Section 143(3)Section 23Section 28Section 72A

income after setting off Neptune Buildcon LLP vs. ITO Asst. Year : 2014-15 3 business losses. Later on, the case was selected for the complete scrutiny on the following grounds: i. That, unsecured loans from persons, who have not filed their Return of income (Form 3CD). ii. That, high Interest

Sivasankar Paidipati, Bhimavaram vs. Income Tax Officer, Ward-1, Bhimavaram

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

ITA 300/VIZ/2024[2018-19]Status: DisposedITAT Visakhapatnam05 Sept 2024AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A. No. 300/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2018-19) Sivasankar Paidipati V. Income Tax Officer – Ward –1 Flat No. 303, 3Rd Floor Income Tax Office, J.P. Road Sri Rama Heights Sivaraopet, Bhimavaram Rayalam Bhimavaram, West Godavari Andhra Pradesh - 534204

Section 115BSection 142(1)Section 143(2)Section 144Section 250Section 68

income on 26.10.2018 declaring an income of Rs.5,83,070 for the A.Y. 2018-19. The case of the assessee has been selected for complete scrutiny on the issue, “Large commission expenses and low net profit” and notice under section 143(2) of the Act was issued on 28.09.2019. Subsequently

Income Tax Officer, Ward-6(2), Jaipur, Ncr Building, Statue Circle Jaipur vs. Vasudev Hemrajani, Arjun Nagar, Jaipur

The appeal of the revenue stands dismissed

ITA 634/JPR/2024[2020-2021]Status: DisposedITAT Jaipur05 Sept 2024AY 2020-2021

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Tarun Mittal, CAFor Respondent: Sh. Anil Dhaka, CIT
Section 115BSection 142(1)Section 143(2)Section 143(3)Section 250Section 68

filed his return of income for A.Y.2020-21 on 29-12-2020 declaring net taxable income at Rs.15,53,040/-. The case was selected for Complete Scrutiny under CASS with the reasons namely, 'Low income compared to large commission receipts' and 'Large cash deposits in bank account(s)'. Accordingly, statutory notice ... aggrieved by the same the appellant has preferred instant appeal. 19 ITO vs. Vasudev Hemrajani The AO stated that the case was selected for Complete Scrutiny under CASS due to 'Low income compared to large commission receipts' and 'Large cash deposits in bank account(s)'. The appellant derived income under

Tyco Electronics Singapore Pte Limited, Bangalore vs. DCIT, Circle- Int. Tax. 3(1)(1), Delhi

The appeal is allowed

ITA 1760/DEL/2022[2017-18]Status: DisposedITAT Delhi05 Sept 2024AY 2017-18

Bench: Dr. B.R.R. Kumar & Shri Anubhav Sharmaassessment Year: 2017-18 Tyco Electronics Singapore Vs Dcit, Pte Limited, Circle Intl. Taxation Te Park-22B, Doddenakundi 3(1)(1), 2Nd Phase Industrial Area, Delhi. Whitefield Road, Bengaluru – 560 048, Karnataka. Pan: Aadct9910C (Appellant) (Respondent) Assessee By : Shri Ajay Vohra, Sr. Advocate & Ms Somya Jain, Ca Revenue By : Shri Vizay B. Vasanta, It-Dr & Shri Anshul, Sr. Dr Date Of Hearing : 05.07.2024 Date Of Pronouncement : 05.09.2024 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Final Assessment Order Dated 23.06.2022 Passed U/S 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’), By Assessing Officer, Circle Int. Taxation 3(1)(1), Delhi (Hereinafter Referred To As The Ld. Ao).

For Appellant: Shri Ajay Vohra, Sr. Advocate &For Respondent: Shri Vizay B. Vasanta, IT-DR &
Section 143(3)

high performance polymeric products, highly specialized energy- related products and other electrical and electronic and electronic components. The return of assessee was picked for complete scrutiny and AO had made addition of Rs. 211,61,53,235/- in the draft assessment order. The AO had denied assessee, being

Wirtgen India Private Limited, Pune vs. DCIT, Circle-12, Pune

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

ITA 788/PUN/2024[2018-19]Status: DisposedITAT Pune04 Sept 2024AY 2018-19

Bench: Shri S.S. Godara & Shri Inturi Rama Rao

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Arvind Desai
Section 142(1)Section 143(1)Section 143(3)Section 250

making adjustment by disallowance of the Employees’ contribution to PF/ESI amounting to Rs.12,71,735/-. Thereafter, the case was selected for Complete Scrutiny for verification of (i) claim of any other amount allowable as deduction in Schedule BP; (2) Default in TDS & Disallowance for such default; (3) Duty drawback