Limited scrutiny assessment cannot support additions beyond selected issues without prior approval and record evidence.

In a limited scrutiny assessment, additions on issues beyond the specified reasons for selection cannot be sustained unless prior written approval to expand the scope is obtained from the competent authority and reflected in the record. Here, the notice under section 143(2) showed scrutiny was confined to MAT liability mismatch and sales turnover mismatch, but the Assessing Officer made additions on other issues without showing the required approval. The assessment was therefore contrary to CBDT instructions and was quashed.

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Issues: Whether the assessment framed in a limited scrutiny case was valid when the Assessing Officer made additions on issues beyond the reasons for scrutiny without obtaining the requisite approval.

Analysis: The notice under section 143(2) showed that the case was selected for limited scrutiny only on specified issues relating to MAT liability mismatch and sales turnover mismatch. The CBDT instructions governing limited scrutiny confined the questionnaire and enquiry to the specified reasons for selection, and widening the scope required prior written approval of the competent authority. The assessment order did not show that such approval had been obtained before making additions on other issues. In these circumstances, the assessment was held to be contrary to the CBDT instructions.

Conclusion: The assessment order was quashed and the ground challenging its validity was accepted.

Ratio Decidendi: In a limited scrutiny assessment, additions on issues beyond the specified scope cannot be sustained unless the prescribed prior approval for expanding the scrutiny is obtained and reflected in the record.

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