https://www.taxtmi.com/caselaws?id=783637 In a limited scrutiny assessment, the AO's jurisdiction was confined to issues flagged under ss. 14A and 68 as per binding CBDT instructions u/s 119; by making an addition u/s 69 beyond those issues, the AO impermissibly converted limited scrutiny into complete scrutiny, rendering the entire assessment order u/s 143(3) void ab initio and liable to be quashed. On merits, succession of a proprietary business to a company satisfied all conditions of s. 47(xiv); alleged asset revaluation/issue of shares above book value was not a prohibited "benefit" and was tax-neutral under s. 49(1), so no capital gains arose u/s 45 and the related s. 68 capital-credit addition was deleted. Gifts from relatives evidenced by registered settlement deeds could not be taxed u/s 68 merely due to valuation differences; the addition was deleted. en-us Mon, 15 Dec 2025 00:00:00 +0530 Fri, 19 Dec 2025 08:30:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783637 In a limited scrutiny assessment, the AO's jurisdiction was confined to issues flagged under ss. 14A and 68 as per binding CBDT instructions u/s 119; by making an addition u/s 69 beyond those issues, the AO impermissibly converted limited scrutiny into complete scrutiny, rendering the entire assessment order u/s 143(3) void ab initio and liable to be quashed. On merits, succession of a proprietary business to a company satisfied all conditions of s. 47(xiv); alleged asset revaluation/issue of shares above book value was not a prohibited "benefit" and was tax-neutral under s. 49(1), so no capital gains arose u/s 45 and the related s. 68 capital-credit addition was deleted. Gifts from relatives evidenced by registered settlement deeds could not be taxed u/s 68 merely due to valuation differences; the addition was deleted. Case-Laws Income Tax Mon, 15 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783637