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Tax Assessment Conversion to Full Scrutiny Violated CBDT Instructions, Lacked Substantial Evidence, and Was Mechanically Approved.
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....Scrutiny assessment - conversion of the case from limited scrutiny to complete scrutiny - Bogus purchases - it is very much apparent that the proposal of converting the limited scrutiny to complete scrutiny was merely aimed at making fishing enquiries. We also note that the Ld. Pr. Commissioner of Income Tax has accorded the approval in a mere mechanical manner which is in clear violation of the CBDT Instructions.....