Limited Scrutiny to Complete Scrutiny Conversion Challenged Due to Lack of Credible Evidence and CBDT Mandate Violation.

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....Conversion of limited scrutiny into complete scrutiny assessment - AO has not referred to any credible or reliable material or information to form the view that there was a possibility of under assessment of income in this case. The AO has merely made certain disallowance on ad hoc basis without pointing out any information or material available to him which has a direct nexus to show that there was possibility of under assessment of income. - Conversion of limited scrutiny into complete scrutiny is against the spirit of CBDT mandate which is binding on the AO. - AT....