The issue under consideration is that once the assessment is framed under section 143(3) for limited scrutiny then can PCIT revise the assessment order on some other issues which is not connected with the issues raised in limited scrutiny by the Assessing Officer.

The Tribunal by relying upon the Instruction No.20/2015 dated 29.12.2015 issued by CBDT observed that in a limited scrutiny case the assessment shall remain confined only to the specific issues for which case has been picked up. The scope of limited scrutiny shall be expanded upon fulfillment of certain conditions. The conditions are that during the course of assessment proceedings in a limited scrutiny case if it comes to the notice of Assessing Officer that there is a potential escapement of income exceeding Rs.5 lakh for normal CIT charge and potential escapement of income exceeding Rs.10 lakh for metro CIT charge requiring substantial verification on any other issue then the case may be taken up for complete scrutiny with the prior approval of PCIT.

In light of the aforesaid circular, the Tribunal held that once the Assessing Officer cannot examine any other issue except the issue as selected for limited scrutiny assessment, the PCIT can examine the only issue which was before the Assessing Officer during the course of scrutiny assessment and not any other issue which has not been subject matter of the Assessing Officer for the assessment in a limited scrutiny assessment. (AY. 2015-16)