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Income Tax - Highlights / Catch Notes

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ITAT ruled that Assessing Officer (AO) did not exceed ...


Tax Officer Can Conduct Full Scrutiny Without Extra Approval When High-Value Financial Transactions Justify Comprehensive Assessment From Start

January 30, 2025

Case Laws     Income Tax     AT

ITAT ruled that Assessing Officer (AO) did not exceed jurisdiction in conducting complete scrutiny without additional approval. Case involved three significant factors: non-submission of mandatory assets/liabilities schedule for high-income taxpayer, substantial lending operations disproportionate to reported income, and significant loan settlements requiring verification. These aspects inherently warranted comprehensive examination beyond limited scrutiny parameters. CIT(A)'s observation regarding procedural non-compliance with CBDT circular for conversion from limited to unlimited scrutiny was deemed erroneous, as initial selection parameters themselves justified complete scrutiny. Given the nature of financial transactions and reporting requirements, case was inherently qualified for comprehensive examination from inception. ITAT held AO's actions were within jurisdictional scope.

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