Limited-scrutiny boundaries restrict revisionary power; fresh assessment cannot be directed on issues outside the selected scrutiny scope.

Revisionary jurisdiction cannot be used to expand a limited-scrutiny assessment beyond the issues for which scrutiny was selected. Where the Assessing Officer examined sales turnover and high-value securities transactions within the prescribed scope and accepted the returned income, unexamined matters relating to audit or estimation of share and futures-and-options income and TDS-related expenditure could not render the assessment erroneous. The revisionary order directing a fresh assessment on those outside-scope matters was invalid; the original assessment was restored.

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Issues: Whether revisionary jurisdiction could be invoked to direct fresh assessment on issues falling outside the scope of a limited scrutiny assessment.

Analysis: The assessment was selected for limited scrutiny of sales turnover and high-value securities transactions. The Assessing Officer issued notices under the applicable limited-scrutiny scope, obtained and considered the relevant information, and accepted the returned income. The proposed revisions concerned audit/estimation of share and futures-and-options business income and disallowance of TDS-related expenditure. These matters could not form the basis for treating the assessment as erroneous merely because they were not separately dealt with, since they lay beyond the jurisdiction conferred for the limited scrutiny. Revisionary power could not be used to broaden the Assessing Officer's limited jurisdiction indirectly.

Conclusion: The revisionary order was invalid and was quashed in favour of the assessee; the original assessment was restored.

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