Limited scrutiny assessments cannot support additions beyond the selected issue; jurisdiction fails when the officer expands the inquiry.

In a limited scrutiny assessment, the Assessing Officer could not travel beyond the specific issue of cash deposits selected under section 143(2) and make an addition based on turnover and estimated business income. The CBDT instructions governing limited scrutiny were binding, and the assessment order's focus on a matter outside the authorised scope lacked jurisdictional support. The impugned addition was therefore deleted. The remaining grounds did not survive independently and were treated as academic.

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Issues: Whether the addition made in the assessment was sustainable when the case had been selected for limited scrutiny only for verification of cash deposits, and whether the Assessing Officer could travel beyond that scope to estimate business income and make the impugned addition.

Analysis: The case was selected under limited scrutiny on the specific issue of cash deposits, as reflected in the notice under section 143(2). The assessment order, however, did not deal with cash deposits and instead proceeded on the basis of turnover and estimation of income. The addition was therefore made on a matter outside the restricted scope of scrutiny. The CBDT instructions governing limited scrutiny were binding on the Assessing Officer, and the assessment could not be expanded on the facts of the case without adherence to those instructions. Since the impugned addition was not connected with the issue for which scrutiny was selected, it lacked jurisdictional support.

Conclusion: The addition was deleted and the assessee succeeded on the main legal ground. The remaining grounds did not survive independently and were treated as academic.

Final Conclusion: The appeal was partly allowed because the jurisdictional challenge to the addition succeeded, while the other grounds were rendered academic.

Ratio Decidendi: In a limited scrutiny assessment, the Assessing Officer cannot sustain an addition on an issue outside the scope of the scrutiny selection, and any such addition is liable to be deleted for want of jurisdiction.

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