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“revised return”

Assessment ProceduresSection 139(5)Section 139(5)10,551 judgments

The decision most relied on for revised return is Goetze (India) Ltd. v. CIT (284 ITR 323), cited in 1,842 judgments on BharatTax.

Leading authorities on revised return

Goetze (India) Ltd. v. CIT
284 ITR 323 · 2006 · Supreme Court
1,842
citing judgments

An assessee cannot raise a new claim or a claim not made in the original or revised return of income for the first time directly before the Assessing Officer during assessment proceedings.

CIT v. Pruthvi Brokers & Shareholders
349 ITR 336 · 2012 · High Court
956
citing judgments

Appellate authorities can entertain fresh claims or revised computations of income made by an assessee, even if these were not submitted through a revised return of income.

CIT v. Jai Parabolic Springs Ltd.
306 ITR 42 · 2008 · High Court
349
citing judgments

An assessee can make an additional claim for deduction or file a revised computation of income during assessment proceedings, even if a revised return of income has not been filed. Such additional claims or grounds can also be admitted at the appellate stage.

CIT v. Infosys Technologies Ltd.
341 ITR 293 · 2012 · High Court
205
citing judgments

A Commissioner can revise an assessment order under Section 263 if it is erroneous and prejudicial to the interests of the revenue. This includes cases where the Assessing Officer fails to make further inquiries before accepting the assessee's statements in the return.

CIT v. Suresh Chandra Mittal
251 ITR 9 · 2001 · Supreme Court
179
citing judgments

A penalty under section 271(1)(c) for concealment or furnishing inaccurate particulars of income is not automatically leviable merely because a higher income is declared, even after a search or in a voluntarily revised return. The initial burden to prove concealment or inaccurate particulars lies with the Revenue.

Duggal & Co. v. CIT
220 ITR 456 · 1996 · High Court
84
citing judgments

An assessment order becomes erroneous and prejudicial to the revenue under Section 263 if the Assessing Officer fails to conduct a proper inquiry or investigation, even if the return appears prima facie correct. The Income-tax Officer has a duty to investigate and cannot remain passive.

Pr. CIT v. Ankit Metal & Power Ltd.
109 Taxmann.com 93 · 2019 · High Court
77
citing judgments

The Income Tax Appellate Tribunal (ITAT) has the power under Section 254 to entertain a claim for deduction not made in the original return of income or a revised return filed before the Assessing Officer.

35. In Virbhadra Singh (HUF) v. Pr. CIT
298 CTR 393 · 2017 · High Court
76
citing judgments

Where no inquiry was conducted by the Assessing Officer in passing an assessment order after accepting a revised return, the Commissioner acts within their power under section 263 to direct a fresh assessment.

Judgments citing revised return

Deputy Commissioner of Income Tax, Chennai vs. Muthulakshmi Vellaisamy, Tirupur

In the result, the appeal filed by the Revenue is dismissed

ITA 610/CHNY/2025[2020-21]Status: DisposedITAT Chennai20 Jan 2026AY 2020-21

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 605/Chny/2025 निर्धारण वर्ष / Assessment Year: 2020-21 Deputy Commissioner Of Income Tax, Central Circle-2(4), Chennai. (अपीलार्थी/Appellant) Gnanaguru Lavanya, Vs. 52, Iswarya Garden, Rakkiyapalayam Road, Ammapalayam, Avinashi Road, Tirupur - 641 654. [Pan: Abipl-5558-M] (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita No.: 610/Chny/2025 निर्धारण वर्ष / Assessment Year: 2020-21 Deputy Commissioner Of Income Tax, Central Circle-2(4), Chennai. Muthulakshmi Vellaisamy, Vs. 52, Iswarya Garden, Rakkiyapalayam Road, Ammapalayam, Avinashi Road, Tirupur - 641 654. [Pan:Afbpg-3703-L] (प्रत्यर्थी/Respondent) (अपीलार्थी/ Appellant) अपीलार्थी की ओर से/Appellant By : Ms. E. Pavuna Sundari, C.I.T. प्रत्यर्थी की ओर से /Respondent By : Shri. R. Venkata Raman, C.A. सुनवाई की तारीख/Date Of Hearing : 12.11.2025 घोषणा की तारीख/Date Of Pronouncement : 20.01.2026 :-2-:

For Appellant: Ms. E. Pavuna Sundari, C.I.TFor Respondent: Shri. R. Venkata Raman, C.A
Section 132Section 132(4)Section 139(4)

lakhs and Rs. 3 lakhs in the house for family expenses and educational expenses of his daughter, respectively. It was also noted that the revised return was filed by the seller wherein he had shown approximately Rs. 2.5 lakhs being available with him in cash. Even after giving the retraction

Rajender Singh Sihag, Hisar vs. Income Tax Officer Ward-1 Hisar, Hisar

Appeal is allowed

ITA 8500/DEL/2025[2023-24]Status: DisposedITAT Delhi20 Jan 2026AY 2023-24

Bench: Sh. Satbeer Singh Godaraita No. 8500/Del/2025 : Asstt. Year: 2023-24 Rajender Singh Sihag, Vs Income Tax Officer, 2022, Sector-14, Hisar, Ward-1, Haryana-125001 Hisar, Haryana-125001 (Appellant) (Respondent) Pan No. Bhzps5598A Assessee By: Sh. Manoj Kumar, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 20.01.2026 Date Of Pronouncement: 20.01.2026 Order This Assessee’S Appeal For Assessment Year 2023-24 Arises Against The Addl./Jcit(A), Raipur’S Din & Order No. Itba/Apl/S/250/2025-26/1082189810(1) Dated 31.10.2025, In Proceedings U/S 143(1) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Manoj Kumar, CAFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 115BSection 139(1)Section 143(1)

length. Case file perused. 3. It emerges during the course of hearing that both the learned lower authorities have rejected the assessee’s revised return admittedly filed under the normal provisions post facto his regular return submitted u/s 139(1) of the Act seeking benefit of the new taxation regime ... before the tribunal. I accordingly find merit in his instant sole substantive ground and direct the learned assessing authority to proceed further with his revised return as per law in very terms. 5. This assessee’s appeal is allowed. Order Pronounced in the Open Court on 22/01/2026. (Satbeer Singh Godara

Cooperative Cane Deve. Union, Ltd., Haridwar vs. ITO, W- 1(3)(1), Haridwar

In the result, appeal of the assessee is partly allowed

ITA 158/DDN/2024[2019-20]Status: DisposedITAT Dehradun16 Jan 2026AY 2019-20

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year: 2019-20] Co-Operative Cane Development Vs Ito Union Limited, Jawalapur, Ward-1(3)(1) Vill. & P.O. Jawalapur, Distt.- Haridwar Haridwar, Uttarakhand-249407 Uttarakhand Pan-Aaaic0152B Appellant Respondent Assessee By None Revenue By Shri Amar Pal Singh, Jcit Dr Date Of Hearing 13.11.2025 Date Of Pronouncement 16.01.2026 Order Per Manish Agarwal, Am : The Captioned Appeal Is Filed By The Assessee Against The Order Dated 26.07.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2018-19/10076885 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Intimation Order Dated 02.12.2020 Passed U/S 143(1) Of The Act Pertaining To Assessment Year 2019-20. 2. At The Time Of Hearing, Assessee Filed The Letter & Stated That The Written Submission Made Be Considered. Therefore, Ld. Sr. Dr Was Heard & Proceeded To Decide The Appeal Filed By The Assessee On The Basis Of Material Available On Record. 3. Brief Facts Of The Case Are That Assessee Is A Co-Operative Society Constituted By The State Government, Engaged In The Business Of Providing Credit Facilities To Its Members Who Are Agriculturists & Cane Growers Also, Marketing Of Agricultural Products & Purchase Of Agricultural Implements & Other Products Like Fertilizers, Insecticides Etc. Assessee Filed Its Return Of Income On 29.08.2019, Declaring Total Income At Nil & Claimed Deduction U/S 80P Of Inr 1,04,54,668/-. Thereafter, The Return Of Income Was Processed U/S 143(1), Assessed Total Income At Inr 1,04,54,668/- Where Deduction U/S 80P Was Not Provided To The Assessee Society.

Section 143(1)Section 143(1)(a)Section 143(3)Section 250Section 80P

Revenue vehemently supported the orders of the lower authorities and submits that CPC has provided many opportunities to the assessee to file revised return of income for making claim of deduction u/s 80P which has not been done therefore, the lower authorities has rightly rejected the same which orders deserve

Prem Singh, Chamba vs. ACIT Circle Palampur, Palampur

In the result, the appeal for AY 2017-18 stands partly allowed

ITA 947/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh15 Jan 2026AY 2017-18

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No. 946/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2015-16) & 2. आयकर अपील सं. / Ita No. 947/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) Shri Prem Singh Dcit Circle, Palampur बनाम/ The Palace. Chamba Himachal Pradesh - 176061 Vs. Himachal Pradesh – 176310 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aampr-8876-P (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Shri Ajay Jain (Ca) – Ld. Ar Revenue By : Shri Bharat Bhushan Garg (Cit) (Virtual) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 13-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 13-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. The Assessee Is In Further Appeals Before Us For Assessment Years (Ay) 2015-16 & 2017-18 Which Arises Out Of Separate Orders Of Learned First Appellate Authority. First, We Take Up Appeal For Assessment Year (Ay) 2015-16 Which Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 22-07-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S 143(3) Of The Act On 29-12-2017. The Assessee Is Aggrieved By Computation Of Capital

For Appellant: Shri Ajay Jain (CA) – Ld. ARFor Respondent: Shri Bharat Bhushan Garg (CIT) (Virtual) - Ld. DR
Section 143(3)Section 48Section 54Section 54F

filed on 05-08-2016. The refund amount was Rs.34,28,960/-. The return was processed and refund was granted. However, the assessee revised return of income on 07-02-2017 which had no refund. The refund amount along with interest amount was deposited on 30-03-2017. The copy ... assessee is in further appeal before us. 22.2 It appears that the assessee has initially received interest on tax refund but apparently, after revised return of income, the said interest has been deposited by the assessee. Therefore, the directions of Ld. CIT(A) are to be endorsed. If the interest

Duckbanglow Para Spark Welfare Society, Birbhum vs. I.T.O., Ward - 3(1), Suri, Birbhum

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 2272/KOL/2025[2018-2019]Status: DisposedITAT Kolkata14 Jan 2026AY 2018-2019

Bench: Shri George Mathanआयकर अपील सं/Ita No.2272/Kol/2025 (नििाारण वर्ा / Assessment Year :2018-2019) Duckbanglow Para Spark Welfare Vs Ito Ward-3(1), Suri, Birbhum Society, C/O Kowsar Ali, Dhulodanga Road Duckbanglow More, Rampurhat, Birbhum, West Bengal-731224 Pan No. :Aadad 5593 P (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri Subhranshu Chima, Ar : Smt. Sima Das Biswas, Sr. Dr राजस्व की ओर से /Revenue By सुनवाई की तारीख / Date Of Hearing : 14/01/2026 घोषणा की तारीख/Date Of Pronouncement : 14/01/2026 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Order Dated 11.08.2025, Passed By The Ld. Addl/Jcit(A), Ranchi For The Assessment Year 2018-2019. 2. It Was Submitted By The Ld. Ar That The Assessee Had By Mistake Filed Its Return Claiming The Status Of A Charitable Organisation Though The Assessee Did Not Have Registration U/S.12A Of The Act. It Was Submission That The Return Filed By The Assessee Came To Be Processed & The Intimation Came To Be Issued Wherein The Application Has Been Treated As Income Of The Assessee. It Was Submission That The Application Filed U/S.154 Of The Act Was Also Rejected. It Was Submission That The Against The Rejection Of Application Filed U/S.154 Of The Act The Assessee Had Filed Appeal To The Cit(A). It Was Submission That The Ld. Cit(A) Has Rejected The Appeal Of The Assessee On The Ground That The Assessee Has Filed The Return Claiming

For Appellant: Shri Subhranshu Chima, AR
Section 12ASection 143(1)Section 154

assessee is not in appeal before the CIT(A). The Ld.AR submitted that the assessee has attempted to file the revised return but due to the online system the returns were not being accepted. The Ld. AR has placed before me the return that is to be filed along with ... assessee to file the same before the AO physically who shall take the same on record and consider the same as the revised return and proceed with the assessment thereon. In the circumstances the appeal of the assessee is partly allowed for statistical purposes. 5. In the result, appeal

Hanuman Agro Industries Ltd., Kolkata vs. DCIT, Circle 4(1), Kolkata

In the result, appeal of the assessee is allowed

ITA 1306/KOL/2025[2018-2019]Status: DisposedITAT Kolkata13 Jan 2026AY 2018-2019

Bench: Shri George Mathanआयकर अपील सं/Ita No.1306/Kol/2025 (नििाारण वर्ा / Assessment Year :2018-2019) Hanuman Agro Industries, Vs Dcit, Circle-4(1), Kolkata Nicco House 6Th Floor, 2 Hare Street Kolkata, West Bengal-700001 Pan No. :Aaach 6578 B (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri S.M.Surana, Advocate राजस्व की ओर से /Revenue By : Shri Abhijit Adhikary, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 13/01/2026 घोषणा की तारीख/Date Of Pronouncement : 13/01/2026 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Order Dated 22.05.2025, Passed By The Ld.Cit(A), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2018-2019. 2. The Ld.Ar Drew My Attention To The Assessment Order Of Page 1 Of First Line Wherein The It Is Mentioned That The Return Of Income For The Impugned Assessment Year Originally Was Filed On 31.10.2018. Subsequently, The Assessee Filed A Revised Return On 19.03.2019, Declaring Total Income Of Rs.16,64,350/-. It Was The Submission That The Assistant Commissioner Of Income Tax, Kolkata-1(2) Has Passed The Assessment Order. It Was The Submission That The Notice U/S.148 Of The Act In The Impugned Assessment Year Was Issued On 25.03.2025 By The Acit, Circle- 4(1), Kolkata. The Ld.Ar Drew My Attention To The Notice Which Is Shown At Page 9 Of The Paper Book Which Reads As Follows :-

For Appellant: Shri S.M.Surana, AdvocateFor Respondent: Shri Abhijit Adhikary, Sr. DR
Section 120Section 148

mentioned that the return of income for the impugned assessment year originally was filed on 31.10.2018. Subsequently, the assessee filed a revised return on 19.03.2019, declaring total income of Rs.16,64,350/-. It was the submission that the Assistant commissioner of Income Tax, Kolkata-1(2) has passed the assessment