https://www.taxtmi.com/caselaws?id=310508 The ITAT Kolkata held that the AO exceeded jurisdiction by making additions beyond the scope of limited scrutiny assessment. The case involved a limited scrutiny notice under section 143(2) covering four specific issues: foreign remittance receipts, related party payment mismatches under section 40A(2)(b), unsecured loans from non-filers, and currency fluctuation losses. The ITAT found the AO's actions violated CBDT Instruction No. 5/2016 dated 14.07.2016, which requires reasonable belief of under-assessment based on credible material, not mere suspicion, before converting limited scrutiny to complete scrutiny. The CIT(A)'s confirmation of additions for issues outside the limited scrutiny scope was deemed improper, following precedent from coordinate bench decision. en-us Tue, 28 Mar 2023 00:00:00 +0530 Sat, 28 Oct 2023 08:35:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310508 The ITAT Kolkata held that the AO exceeded jurisdiction by making additions beyond the scope of limited scrutiny assessment. The case involved a limited scrutiny notice under section 143(2) covering four specific issues: foreign remittance receipts, related party payment mismatches under section 40A(2)(b), unsecured loans from non-filers, and currency fluctuation losses. The ITAT found the AO's actions violated CBDT Instruction No. 5/2016 dated 14.07.2016, which requires reasonable belief of under-assessment based on credible material, not mere suspicion, before converting limited scrutiny to complete scrutiny. The CIT(A)'s confirmation of additions for issues outside the limited scrutiny scope was deemed improper, following precedent from coordinate bench decision. Case-Laws Income Tax Tue, 28 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310508