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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

Rajnesh Kumar Aggarwal, Nehru Place, Delhi vs. Income Tax Officer. Ward 30(4), Delhi

ITA 1989/DEL/2023[2016-17]Status: DisposedITAT Delhi21 Aug 2024AY 2016-17

Bench: Shri Shamim Yahya & Shri Narinder Kumarassessment Year: 2016-17 Rajnesh Kumar Aggarwal Vs. Income Tax Officer, Ward 30(4), 1116, Devika Towers, 6 Nehru Place, New Delhi New Delhi-110019 Pan :..Afqpa1657L (Appellant) (Respondent)

Section 133(6)Section 142(1)Section 143(2)Section 271(1)(c)Section 274Section 68

reveals that after filing of return of income by the assessee for the Assessment Year 2016-17, was selected for scrutiny under CASS, for complete scrutiny, whereupon notice u/s 143(2) of the Act was issued and served upon the assessee, followed by another notice u/s 142(1) accompanied

Bhagwatikripa Paper Mills Pvt Ltd, Jaipur vs. Deputy Commissioner of Income Tax, Circle-6, Jaipur

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

ITA 926/JPR/2024[2014-15]Status: DisposedITAT Jaipur20 Aug 2024AY 2014-15

Bench: Or At The Time Of Hearing.”

For Appellant: Shri S.L. Poddar (Adv.)For Respondent: Shri Ajey Malik (CIT)
Section 143(2)Section 143(3)Section 144BSection 147Section 148Section 151Section 194HSection 69C

filed along with computation of total income is available on Paper Book Page No1-4. The case of the assessee was selected for complete scrutiny under CASS and assessment was completed u/s 143(3) on 16/12/2016, determining total income at Rs. 1,39,40,420/-. The copy of assessment order

Akshay Infrasys Industries Pvt. Ltd., Jaipur vs. ITO, Ward-4(1), Jaipur

In the result, the appeal of the assessee is allowed

ITA 613/JPR/2024[2017-18]Status: DisposedITAT Jaipur20 Aug 2024AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Anoop Singh (Addl.CIT)
Section 143(2)Section 143(3)

Return of income was filed in ITR 6 declaring income at Rs. 6,94,970 on 30.11.2017. The case was selected under complete scrutiny through CASS. A notice u/s 143(2) of the I. T. Act, 1961 was issued on 09.08.2018, which was duly served upon the assessee. The statutory

Lexicon Finance Limited, Mumbai vs. DCIT2.2.1, Mumbai

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

ITA 497/MUM/2024[2017-18]Status: DisposedITAT Mumbai20 Aug 2024AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Gagan Goyalassessment Year: 2017-18

For Appellant: Shri Nishit Gandhi, AdvocateFor Respondent: Shri Manoj Kumar Sinha, SR. DR
Section 143(3)Section 144Section 250Section 68

That the Assessee had declared its total income of Rs.1,16,53,120/- by filing its return income on 31.10.2017, which was selected for complete scrutiny and consequently a notice dated 05.09.2018 u/s 143(3) of the Act was issued to the Assessee, in response to which, the Assessee vide

ITO-23(3)(6), Mumbai vs. V. P. Bullion, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 1358/MUM/2024[2017-18]Status: DisposedITAT Mumbai20 Aug 2024AY 2017-18

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri Satyaprakash SinghFor Respondent: Shri Surendra Meena, Sr. DR
Section 131Section 142(1)Section 143(2)Section 143(3)Section 250Section 68

return of income on 27/10/2017 declaring a total income of Rs. 5,72,390. 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 2 | P a g e V.P. Bullion. issued

New Leaf Homes Pvt Limited, New Delhi vs. ITO, Ward 18(3), Delhi, New Delhi

Appeal is allowed for statistical purposes

ITA 2295/DEL/2024[2017-18]Status: DisposedITAT Delhi20 Aug 2024AY 2017-18

Bench: Shri Kul Bharatassessment Year: 2017-18

Section 144Section 282

assessee filed its return of income electronically on 31.10.2017 declaring a loss of (-) Rs.25,87,924/-. The case was selected under complete scrutiny through CASS. The assessee did not respond to the statutory notices issues by the AO. Therefore, the AO completed the assessment ex parte to the assessee

Modest and Parsons International Private Limited, Mumbai Maharashtra vs. Deputy Commissioner of Income Tax 2(2)(2) Mumbai, Mumbai Maharashtra

In the result, the appeal by the assessee for the assessment year 2018-19

ITA 1510/MUM/2024[2015-16]Status: DisposedITAT Mumbai19 Aug 2024AY 2015-16

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri Anant PaiFor Respondent: Shri Ankush Kapoor, CITDR
Section 142(1)Section 143(2)Section 250Section 68

return of income on 30/10/2015 declaring a total income of Rs.2,95,74,950. The return filed by the assessee was selected for complete scrutiny under the CASS module and statutory notices under section 143(2) as well as section 142(1) of the Act were issued and served

Assistant Commissioner of Income Tax- Circle 4(2)(1), Mumbai vs. First Advantage Private Limited, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 1380/MUM/2024[2017-18]Status: DisposedITAT Mumbai16 Aug 2024AY 2017-18

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh Joshi/Ms SonakshiFor Respondent: Shri Surendra Meena, Sr. DR
Section 115JSection 142(1)Section 143(2)Section 143(3)Section 250Section 40

provisions and book profit under section 115JB of the Act at Rs.8,10,93,284. 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

Shenbagam Hospitals Private Limited, Madurai vs. ACIT Corp. Circle 2, Madurai

In the result, appeal filed by the assessee is allowed

ITA 836/CHNY/2024[2017-18]Status: DisposedITAT Chennai14 Aug 2024AY 2017-18

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.836/Chny/2024 (िनधा"रणवष" / Assessment Year: 2017 -2018) Shenbagam Hospitals Private Limited, Vs. The Assistant Commissioner Of 15A, North Cross, Income Tax, 3Rd Street, Corporate Circle 2, Anna Nagar, Madurai. Madurai 625 020. [Pan: Aahcs 1403M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri P.M. Kathir, Advocate ""यथ" क" ओर से /Respondent By : Ms Gouthami Manivasagam, Irs, Jcit सुनवाई क" तार"ख/Date Of Hearing : 12.08.2024 घोषणा क" तार"ख /Date Of Pronouncement : 14.08.2024 आदेश / O R D E R Per Manu Kumar Giri ()

For Appellant: Shri P.M. Kathir, AdvocateFor Respondent: Ms Gouthami Manivasagam, IRS, JCIT
Section 115JSection 142(1)Section 143(2)Section 143(3)Section 44ASection 68

income of Rs.26,26,990/- and deemed income of Rs. 18,86,370/- u/s. 115JB of the IT Act. The case was selected for complete scrutiny under CASS. Therefore, notice u/s. 143(2) of the Act was issued. Subsequently, notices u/s. 142(1) & u/s143(3) of the act were issued

Dy. Commissioner of Income Tax, Chennai vs. Napc Pvt. Ltd., Chennai

ITA 623/CHNY/2024[2018-19]Status: DisposedITAT Chennai14 Aug 2024AY 2018-19

Bench: Shri Manu Kumar Giri, Hon'Ble & Shri S. R. Raghunatha, Hon'Bleआयकरअपीलसं./Ita No.: 623/Chny/2024 निर्धारणवर्ष / Assessment Year: 2018-19 Dy. Commissioner Of Income Tax, Central Circle-2(1) No. 46, M.G. Road, Nungambakkam, Chennai - 600 034. (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख/Date Of Pronouncement : V. : Shri. : Shri. : 01.07.2024 : 14.08.2024 Napc Pvt Ltd., No.3, 6Th Floor, Apex Plaza, Nungambakkam High Road, Nungambakkam – 600 034. [Pan: Aaccn-3625-P] (प्रत्यर्थी/Respondent) V. Nandakumar, Cit T. Banusekar, Advocate & Shri. Suraj Nahar, Ca आदेश /Order Per S. R. Raghunatha: This Appeal By The Revenue Is Filed Against The Order Of The Commissioner Of Income Tax (Appeals), Chennai-19, For The

Section 143(1)Section 143(3)Section 145(3)Section 36(1)(va)Section 41(1)Section 43C

U/s.36(1)(va) of the Act, by reducing the loss to Rs.22,11,35,747/-. Further, the case was selected for complete scrutiny and statutory notices were issued to the assessee. The AO thereafter completed the assessment U/s.143(3) r.w.s.144B vide order dated 18/09/2021 assessed income at Rs.43

Mohd Umeed, Delhi vs. Income Tax Officer, Delhi

In the result, the appeal of the assessee is allowed

ITA 327/DEL/2024[2017-18]Status: DisposedITAT Delhi14 Aug 2024AY 2017-18

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Shailesh Gupta, AdvFor Respondent: Sh. Anshul, Sr. DR
Section 143(1)Section 143(3)Section 694Section 69A

which was processed u/s 143(1) of the Income Tax Act, 1961. Subsequently, the case was selected under CASS for complete scrutiny on the ground of large cash deposited. During the year under consideration, the assessee has been in the business of trading of live birds. The assessee has declared

Anudita Jawahar Datta, Pune vs. ITO, Ward 3(3), Pune

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

ITA 1137/PUN/2024[2016-17]Status: DisposedITAT Pune13 Aug 2024AY 2016-17

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.1137/Pun/2024 "नधा"रण वष" / Assessment Year : 2016-17

For Appellant: Shri Naimish DixitFor Respondent: Shri Rajesh Gawali
Section 143(2)Section 144

filed the Return of Income for the A.Y. 2016-17 on 13.12.2016 disclosing total income of Rs.5,66,770/-. The case was selected for Complete Scrutiny under CASS. Statutory notices u/s.143(2) and 142(1) were issued to the appellant to which there was no compliance from the side

ITO 17(3)(1), Bkc, Bandra(E) vs. Hakimuddin Saleh Porbunderwala, Mumbai

In the result, the appeal filed by the Revenue Department stands dismissed

ITA 3248/MUM/2024[2021-22]Status: DisposedITAT Mumbai13 Aug 2024AY 2021-22

Bench: Shri Narender Kumar Choudhry & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

For Appellant: NoneFor Respondent: Shri P.D. Chougule, (Addl. CIT) Sr. DR
Section 133(6)Section 143(3)Section 250Section 271ASection 69C

order, grounds of appeal and written submission filed by the appellant. I find from the assessment order that the case was selected for scrutiny complete scrutiny under E-assessment scheme for checking the genuineness of the purchases from the high-risk billers. During the course of assessment proceedings the appellant

Ajay Paliwal, Panipat vs. Income Tax Officer, Ward-11(1), Delhi

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

ITA 1243/DEL/2024[2017-18]Status: DisposedITAT Delhi13 Aug 2024AY 2017-18

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.1243/िद"ी/2024 (िन.व. 2017-18) Ajay Paliwal, Paliwal Nagar, G.T Road, Panipat, Haryana 132103 ...... अपीलाथ"/Appellant Pan: Acwpp-2890-B बनाम Vs. Income Tax Officer, Ward-11(1), ..... "ितवादी/Respondent C.R Building, Ito, I.P Estate, Delhi 110002 अपीलाथ" "ारा/ Appellant By : Shri Amit Kaushik, Advocate "ितवादी"ारा/Respondent By : Shri Kanv Bali, Sr.Dr सुनवाई क" ितिथ/ Date Of Hearing : 13/08/2024 घोषणा क" ितिथ/ Date Of Pronouncement : 13/08/2024 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short ‘The Cit(A)’] Dated 23.02.2024, For Assessment Year 2017-18. 2. The Assessee In Appeal Has Primarily Raised Two Issues. In Ground No. 1 Of Appeal The Assessee Has Assailed The Jurisdiction Of Assessing Officer (Ao) & In Ground No. 2 To 5 Of Appeal The Assessee Has Assailed Addition Of Rs 21,00,000/- U/S. 69A Of The Income Tax Act, 1961(Hereinafter Referred To As 'The Act').

For Appellant: Shri Amit Kaushik, AdvocateFor Respondent: Shri Kanv Bali, Sr.DR
Section 143(3)Section 69A

senior citizen. He filed his return of income declaring total income of Rs. 48,07,640/-. The case of assessee was selected for complete scrutiny under CASS. The assessment was completed vide order dated 23.12.2019 u/s. 143(3) of the Act by Income Tax Officer (ITO). He referred to CBDT

Chalasani Hospitals Pvt Ltd, Visakhapatnam vs. Assistant Commissioner of Income Tax, Circle-1(1), Visakhapatnam

In the result, appeal of the assessee is dismissed and the cross objection of the revenue is allowed

ITA 315/VIZ/2023[2018-19]Status: DisposedITAT Visakhapatnam12 Aug 2024AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.315/Viz/2023 (निर्धारण वर्ा/ Assessment Year: 2018-19) Chalasani Hospitals (P.) Ltd., V. Asst. Commissioner Of Income Tax Central Circle – 1(1) D.No. 50-53-14, Gurudwara Lane Income Tax Office Seethammadhara Direct Taxes Building Visakhapatnam – 530013 Mvp Colony, Visakhapatnam -530017 Andhra Pradesh Andhra Pradesh [Pan :Aaecc0005G] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 142(1)Section 143(1)Section 143(3)Section 37(1)

payments. Subsequently, the Page No. 2 I.T.A. No. 315/VIZ/2023 & C.O. No. 02/VIZ/2024 Chalasani Hospitals (P.) Ltd., case was selected for complete scrutiny for verifying the following issues: - i. Default in TDS & Disallowance for such Default ii. Refund Claim 3. Thereafter, statutory notices under section

Smt. Pawan Paras Jain, Mumbai vs. Income Tax Officer Ward 19(2)(5), Mumbai

In the result, ground number 6 of the appeal of the assessee is allowed with above direction, in view of this, other grounds are not required to be adjudicated hence dismissed

ITA 471/MUM/2024[2015-16]Status: DisposedITAT Mumbai12 Aug 2024AY 2015-16

Bench: BeforeShri Prashant Maharishi( (Accountant Member)

Section 10Section 131Section 143Section 68

detailed working of the same is not submitted by the assessee before the learned assessing officer. The reason for the selection of the complete scrutiny of the return of income was to examine the suspicious sale transaction in shares and exempt long-term capital gain shown in the return

Kapil Alcotech LLP, Aurangabad vs. Deputy Commissioner of Income Tax Circle - 1, Aurangabad

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

ITA 557/PUN/2024[2020-21]Status: DisposedITAT Pune09 Aug 2024AY 2020-21

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2020-21

For Appellant: Shri K P DewaniFor Respondent: Shri Pankaj Kumar
Section 143(2)Section 143(3)Section 250Section 250(1)Section 68Section 69C

IMFL) at Aurangabad. It had filed its return of income on 01.01.2021 declaring total income of Rs.49,51,589/-. The case was selected for complete scrutiny. Accordingly, statutory notices u/s 143(2) and 142(1) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) were issued

Gurukripa West End, Indore vs. ITO-5(5), Indore

In the result appeal of the assessee is allowed

ITA 184/IND/2024[2015-16]Status: HeardITAT Indore09 Aug 2024AY 2015-16

Bench: Shri Manish Boradgurukripa West End, Income Tax Officer 5(5), M-9 Akashdeep Compex, Indore 21 Sneh Nagar, Vs. Sapna Sangeeta Road, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aamfg2439D Assessee By S/Shri Pankaj Shah & Soyumya Bumb, Ars Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 06.08.2024 Date Of Pronouncement 09.08.2024 O R D E R

Section 143(1)(a)Section 143(2)Section 143(3)

notices u/s 143(2) and 142(1) of the Act. Though the case was selected for limited scrutiny but subsequently it was converted into complete scrutiny. The reason for selecting the case for scrutiny is that “there is a difference in the value of closing stock shown

Jaspreet Kaur, Delhi vs. Income Tax Officer Ward 45 (2), Delhi

The appeal of the assessee is allowed

ITA 13/DEL/2024[2017-18]Status: DisposedITAT Delhi08 Aug 2024AY 2017-18

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishra

Section 143(3)Section 44ASection 69A

submitted that the present case was squarely covered by this decision. 4.1 The Second issue was raised with respect to limited scrutiny and complete scrutiny it was contended that the case was selected for limited scrutiny; however, it was converted to full scrutiny without approval of the PCIT. Hence

Parveen Banu Hebbal, Hyderabad vs. Income Tax Officer, Ward-8(1), Hyderabad

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

ITA 658/HYD/2024[2020-21]Status: DisposedITAT Hyderabad07 Aug 2024AY 2020-21

Bench: Shri Laliet Kumarassessment Year: 2020-21 Parveen Banu Hebbal, Vs. The Income Tax Officer, 8-2-603/13/3/N/1/A, Ward – 8(1), 1St Floor, Singara Colony, Hyderabad. Banjara Hills, Road No.10, Telangana – 500034. Pan : Abxph4274M. (Appellant) (Respondent) Assessee By: Ms. S. Sandhya, Advocate Revenue By: Shri Ashish Kumar Sukhla, Sr.Ar Date Of Hearing: 07.08.2024 Date Of Pronouncement: 07.08.2024

For Appellant: Ms. S. Sandhya, AdvocateFor Respondent: Shri Ashish Kumar Sukhla
Section 143(1)Section 143(2)Section 143(3)Section 68Section 80G

return was processed by CPC u/s 143(1) of the Act. Subsequently, the assessee’s case was selected under CASS for complete scrutiny and notices u/s 143(2) and 142(1) of the Act were issued. In response to 2 the said notices, assessee filed requisite information and submitted explanation