ITAT held revision u/s 263 could not address issues beyond limited scrutiny under CASS

Avinash Chalana and Company Vs PCIT (ITAT Indore)

Conclusion: An issue which was not a point in limited scrutiny under CASS could not be taken up in the proceeding u/s 263 as an appropriate remedy for such an issue was either the AO would have obtained the approval of the competent authority for expanding the limited scrutiny to the full scrutiny or the remedy if possible available u/s 147/148.

Held: Assessee-partnership firm had filed its income tax return declaring income. The case was selected for limited scrutiny, focusing on the issues

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