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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

Western India Cashew Company Private Limited, R. P. Towers vs. Principal Commissioner of Income Tax, Coimbatore

ITA 859/CHNY/2024[2020-21]Status: DisposedITAT Chennai04 Sept 2024AY 2020-21

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.859/Chny/2024 निर्धारण वर्ष / Assessment Year: 2020-21 Western India Cashew Company The Principal Commissioner Of Pvt. Ltd., Vs. Income Tax, No.88, Rp Towers, Coimbatore - 1. Coimbatore Road, Pollachi - 642 002. [Pan: Aaacw 3202B] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Shri G. Surendarnath Rao, C.A प्रत्यर्थी की ओर से /Revenue By : Shri V. Nandakumar, Cit सुनवाई की तारीख/Date Of Hearing : 27.06.2024 घोषणा की तारीख / Date Of Pronouncement : 04.09.2024 आदेश / Order Per S.R. Raghunatha, A.M : This Appeal By The Assessee Is Arising Out Of The Order Of The Principal Commissioner Of Income Tax, Coimbatore-1 (Hereinafter “Pcit”] In Din & Order No. Itba/Rev/F/Rev5/2023- 24/1060503232(1), Dated 05.02.2024. The Assessment Was Framed By The Assessing Officer For The Assessment Year 2020-21 U/S.143(3) R.W.S 144B Of The Income Tax Act, 1961 (Hereinafter The 'Act'), Vide Order Dated 06.09.2022.

For Appellant: Shri G. Surendarnath Rao, C.AFor Respondent: Shri V. Nandakumar, CIT
Section 143(3)Section 263Section 40A(2)

declaring total income at Rs.23,12,01,240/-. The return of income was processed u/s.143(1) on 24.12.2021. The case was selected for complete scrutiny through CASS. The assessment was completed vide Order u/s.143(3) on 06.09.2022, as per which the returned income was accepted. Subsequently, on 21.11.2023, Principal Commissioner ... instant case have been carefully perused. The scrutiny assessment in the instant case was handled by the National Faceless Assessment Centre under complete scrutiny category. The Faceless Assessing Officer had Completed the assessment proceedings by accepting the returned income. Prima facie perusal of the assessee's financials revealed that there

Star Health and Allied Insurance Co. Ltd., Chennai vs. ACIT, NFAC, Delhi

The appeal stands dismissed

ITA 1552/CHNY/2024[2018-19]Status: DisposedITAT Chennai03 Sept 2024AY 2018-19

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1552/Chny/2024 (िनधा*रणवष* / Assessment Year: 2018-19) M/S Star Health & Allied Insurance Pr.Cit Company Limited Chennai-3. बनाम/ #148, Acropolis, Vs. Dr. Radha Krishnan Salai, Mylapore, Chennai-600 004. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aajcs-4517-L (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri P.S. Prabhakar (Ca) - Ld.Ar " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 22-08-2024 घोषणाकीतारीख /Date Of Pronouncement : 03-09-2024 आदेश / O R D E R

For Appellant: Shri P.S. Prabhakar (CA) - Ld.ARFor Respondent: Shri Nilay Baran Som (CIT) - Ld. DR
Section 115JSection 143(3)Section 147Section 263

perusal of case records, our adjudication would be as under. 3. From case records, it emerges that the assessee’s case was selected for complete scrutiny and various issues were identified therein viz. investments / advances / loans, Default in TDS, refund claim and ICDS compliance etc. The assessee furnished reply along ... before us. Our findings and Adjudication 8. Upon perusal of case records, it could be seen that the assessee’s case was selected for complete scrutiny and various issues were identified therein viz. investments / advances / loans, Default in TDS, refund claim and ICDS compliance etc. Notice

Shanthi Gold House, Chennai vs. ITO, Non Corporate Ward-1(6), Chennai

In the result, the appeal of the assesse is dismissed

ITA 746/CHNY/2024[2017-18]Status: DisposedITAT Chennai30 Aug 2024AY 2017-18

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita No.746/Chny/2024 निर्धारण वर्ा /Assessment Years: 2017-18 Shanthi Gold House, Income Tax Officer, No.72, Usman Road, T.Nagar, Non-Corporate Ward-1(6), Chennai -600 017. Chennai [Pan: Aaafs1612C] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Shri S.Girish Kumar, Advocate प्रत्यर्थी की ओर से /Respondent By : Shri V.Nandakumar, Cit सुनवाई की तारीख/Date Of Hearing : 18.07.2024 घोषणा की तारीख /Date Of Pronouncement : 30.08.2024

For Appellant: Shri S.Girish Kumar, AdvocateFor Respondent: Shri V.Nandakumar, CIT
Section 143(3)Section 263Section 269SSection 271DSection 40A(3)

original Return of Income for AY 2017-18 on 24.10.2017 declaring a total income of Rs.1,15,040/-, The case was selected for complete scrutiny under CASS on the issue of cash deposits made into its Bank account during demonetization period and assessment was completed ... erroneous in so far as it is prejudicial to the interest of the Revenue. Material on records indicate that the case selected for complete scrutiny under CASS on the issue of cash deposits made in its bank accounts during demonetization period. The PCIT noted that copies of ledger