Assessee’s case was selected for limited scrutiny with respect to interest expenses, income from real estate business, sales turnover mismatch and other expenses claimed in the profit and loss account.The Assessing Officer started enquiries in respect of secured and unsecured loans prior to date when limited scrutiny was converted into complete scrutiny  and made addition under section 68 of the Act. On appeal the Tribunal held that Instruction No. 5/2016 which provided that while proposing to take up complete scrutiny which was fixed for limited scrutiny, Assessing Officer shall form a reasonable view that there was a possibility of under-assessment of income if case was not examined under complete scrutiny and that plea had to be on existence of credible material not merely on suspicion and conjecture or unreliable sources. Accordingly the conversion of limited scrutiny to complete scrutiny could not be upheld as same was found to be in total violation of Instruction No. 5/2016. (AY. 2015-16)