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2022 (8) TMI 1336 - AT - Income TaxExceeding scope of the prescribed “limited” scrutiny - addition u/s 68 - HELD THAT:- As assessee’s paper book contains the assessee’s limited scrutiny notice indicating that the sole issue in his case as “interest income mismatch” whereas the corresponding Section 143(3) assessment added Section 68 unexplained cash credit and that too, without converting it into a “complete” scrutiny as prescribed in the CBDT circular dated 14.07.2016 baring No. 5/2016. DR could also not place on record any material that the Assessing Officer had indeed undertaken all necessary steps as well as all approval(s) as prescribed in the foregoing twin CBDT circulars. Case law [2020 (10) TMI 425 - MADRAS HIGH COURT] Padmavati (Mad) (HC) holds that such an assessment could not exceed the scope of the prescribed “limited” scrutiny except as per the due process of law. This is indeed coupled with various coordinate benches decisions reiterating the very legal proposition. Faced with this situation, we hold that the learned Assessing Officer’s impugned assessment herein is non- est in the eyes of law.
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