“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

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

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

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

Abhishek Jayketu Joshi, Mumbai vs. Ac Cir-42(2)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5775/MUM/2025[2019-20]Status: DisposedITAT Mumbai13 Jan 2026AY 2019-20

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokarabhishek Jayketu Joshi Ac Cir-42(2)(1), C-73, Venus Society, R. G. Kautilya Bhavan, Thadani Marg, Worli Sea Vs. Mumbai-400 051 Face, Mumbai-400 018 Pan/Gir No. Ackpj8583H (Applicant) (Respondent) Assessee By Shri M. M. Golvala, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 07.01.2026 Date Of Pronouncement 13.01.2026

Section 132Section 132(4)Section 139(1)Section 139(5)Section 143(1)Section 144BSection 147Section 148Section 148ASection 250

after claiming deductions aggregating to Rs. 6,85,000/- from a gross total income of Rs. 1,55,61,223/-. Subsequently, a revised return under section 139(5) was filed on 25.10.2019, declaring the same total income, with an additional disclosure of TCS of Rs. 19,090/- .In the return

Rama Rao Venu Gopala Rao, Tamil Nadu vs. Income Tax Officer, Ward 1, Tamil Nadu

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 2877/CHNY/2025[2019-20]Status: DisposedITAT Chennai12 Jan 2026AY 2019-20

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Shri. Amit Rai, C.A. (Virtual)For Respondent: Shri. K. Ilaiyaraja, Addl. C.I.T

Section 143(3)Section 89

Assessing Officer (AO) dated 23.09.2021. 2. Brief facts of the case are that the assessee is an individual and has filed his revised return of income on 30.07.2020 for A.Y.2019-20, declaring total income of Rs.44,73,340/-. The assessee had claimed relief u/s.89 of the Act for an amount

Sundaram Subramanian Rep. by Legal Heir S Sundaram, Pudukkottai vs. ITO, Circle-2(1), Trichy

In the result, both the appeals of the Assessee are partly allowed

ITA 2420/CHNY/2025[2014-15]Status: DisposedITAT Chennai12 Jan 2026AY 2014-15

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. Y. Sridhar, F.C.AFor Respondent: Shri. Shiva Srinivas, C.I.T

Section 147Section 148Section 251Section 68

stands at Rs.17,66,970/- for A.Y. 2013-14 and Rs.13,61,009/- for A.Y.2014-15, any further intervention to the income disclosed in the revised returns, was submitted to be unsolicited. 13. On the action on part of the ld.CIT(A) to modify the section under which the addition

Sundaram Subramanian, Pudukkottai vs. ITO, Circle-2(1), Trichy

In the result, both the appeals of the Assessee are partly allowed

ITA 2419/CHNY/2025[2013-14]Status: DisposedITAT Chennai12 Jan 2026AY 2013-14

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. Y. Sridhar, F.C.AFor Respondent: Shri. Shiva Srinivas, C.I.T

Section 147Section 148Section 251Section 68

Flourish Techno & Real Estate Private Limited, R T Nagar, Bangalore vs. Income Tax Officer- Ward 3(1)(1), ITO, Bangalore

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

ITA 2435/BANG/2024[2016-17]Status: DisposedITAT Bangalore12 Jan 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2016-17

For Appellant: NoneFor Respondent: Shri Balusamy N, JCIT-DR

Section 142(1)Section 143(2)Section 250Section 271(1)(c)Section 68

case on 29/09/2016 and during the course of survey proceedings, the assessee declared an additional income of Rs. 1,25,00,000/-. A revised return was also filed on 03/04/2017. Thereafter notice u/s. 143(2) was issued on 20/09/2018 and several notices u/s. 142(1) were issued calling

Jerambhai Ratnabhai Patel, Ahmedabad vs. CPC, Bangalore Present Jurisdiction the ITO, Ward-5(1)(2), Ahmedabad

In the result, the appeal of the assessee is dismissed

ITA 1531/AHD/2024[2022-23]Status: DisposedITAT Ahmedabad09 Jan 2026AY 2022-23

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year 2022-23

For Appellant: Shri Vijay H Patel, A.RFor Respondent: Shri Rameshwar P Meena, Sr. DR

Section 139(1)Section 143(1)Section 199

Credit in the hands of the assessee, as assessee has shown capital gain arising from sale of units of his ownership, he filed revised Return of Income on 07.12.2022 declaring total income of Rs. 5,40,311/- and claiming the refund amount of Rs. 9,93,710/- after considering ... determining total income at Rs. 5,40,311/- and refund due of Rs. 11,960/-. The Assessee once again filed revised Return of Income on 30.12.2022 without modifying total income and claiming refund amount of Rs. 9,93,710/-. I.T.A No. 1531/Ahd/2024 Jerambhai Ratnabhai Patel

Devi Manubhai Shah, Mumbai vs. ITO - Circle 32(1), Mumbai

ITA 7005/MUM/2025[2012-13]Status: DisposedITAT Mumbai09 Jan 2026AY 2012-13

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Piyush ChhajedFor Respondent: Shri Annavaran Kosuri

Section 143(1)Section 143(3)Section 147Section 54F

assessment for the Assessment Year 2012-2013: “ The assessee is an individual. As per ITD system, it is seen that the assessee has filed revised return of income for A.Y 2012-13 on 29.10.2012 declaring total income of Rs.24,04,600/-. The return has been processed

Prime Omkar K K Consortium, Mumbai City vs. Income Tax Officer, Ward 25 (3) (1), Mumbai

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

ITA 6541/MUM/2025[2012-13]Status: DisposedITAT Mumbai09 Jan 2026AY 2012-13

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Prusethprime Omkar K K Vs. Income Tax Officer, Ward 25(3)(1) Consortium Income Tax Office, Kautilya Bhavan, Building No. 1, Bandra Kurla Complex, Bandra (East), Sukhadwala, 36 Dhanji Mumbai -400051. Street, Mumbai-400003. Pan/Gir No: Aabap7015N (Appellant) (Respondent)

Section 132Section 132(4)Section 143(2)Section 250Section 68

alter or delete any of the above grounds of appeal.” 3. Facts of the case, in brief, are that the assessee filed revised return of income on 07.09.2012 declaring total income of Rs. 77,30,682/-. The case was taken up for scrutiny under CASS and various statutory notices

Fcs Computer Systems S Pte Ltd, India vs. Assistant Commissioner of Income Tax, Circle Int Tax 1(3)(1), India

In the result, the appeal of the Assessee is allowed

ITA 1034/DEL/2025[2022-23]Status: DisposedITAT Delhi09 Jan 2026AY 2022-23

Bench: Shri M. Balaganesh & Shri Vimal Kumarfcs Computer Systems S Pte Ltd, Vs. Acit, Office No. 07, 5Th Floor, A-40, I- International Taxation- Thum Tower-C, Sector-62, Up 1(3)(1), Delhi (Appellant) (Respondent) Pan: Aaacf7319J Assessee By : Shri Ashwani Taneja, Adv Shri Divyansh Dubery, Adv Shri Shivam Kukreja, Adv Ms. Ria Toyal, Adv Revenue By: Ms. Ekta Jain, Cit Dr Date Of Hearing 04/12/2025 Date Of Pronouncement 09/01/2026

For Appellant: Shri Ashwani Taneja, AdvFor Respondent: Ms. Ekta Jain, CIT DR

Section 143(3)Section 144C

branch office. 5. The return of income for the assessment year 2022-23 was filed by the Assessee on 31-10-2022 and a revised return on 30-12-2022, declaring total income at Rs. Nil under normal provisions of the Act and book profit

Deputy Commissioner of Income Tax, Circle-4(2), Delhi vs. Crystal Crop Protection Limited, Delhi

Accordingly, we find no error in the order of Ld. CIT(A) which is hereby uphold. Accordingly, grounds of appeal No. 2 & 3 of the Revenue are dismissed

ITA 2379/DEL/2023[2013-14]Status: DisposedITAT Delhi09 Jan 2026AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalita No.2330/Del/2023 (Assessment Year 2018-19) Dy. Cit, Crystal Crop Protection Circle-4(2), Delhi. Limited, Vs. B-95, Wazirpur, Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) C.O. No.159/Del/2023 Arising Out Of Ita No.2330/Del/2023 (Assessment Year 2018-19) Crystal Crop Protection Dy. Cit, Limited, Circle-4(2), Delhi. B-95, Wazirpur, Vs. Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) Assessee By Shri S.S. Nagar, Ca Department By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 30.10.2025 Date Of Pronouncement 09.01.2026 C.O. No.159/Del/2023 Dcit Vs. Crystal Crop Protection Limited O R D E R Per Manish Agarwal, Am: The Captioned Two Appeals Are Filed By The Revenue & Cross Objection Is Filed By The Assessee For Following Assessment Years.

Section 1Section 143(3)Section 148Section 37(1)

that they did not form part of assessee's original return and that the assessee had not made a course correction by filing a revised return. 15.1 This view was based, as noticed above, on the judgment of the Supreme Court rendered in Goetze (India) Ltd. (supra

DCIT Circle 4(2), New Delhi vs. Crystal Crop Protection Limited, Delhi

Accordingly, we find no error in the order of Ld. CIT(A) which is hereby uphold. Accordingly, grounds of appeal No. 2 & 3 of the Revenue are dismissed

ITA 2330/DEL/2023[2018-19]Status: DisposedITAT Delhi09 Jan 2026AY 2018-19

Section 1Section 143(3)Section 148Section 37(1)

Pinnacle Consrto and Ecohomes Pvt.Ltd, Pune vs. DCIT Circle-4, Pune

In the result, appeal filed by the assessee is allowed

ITA 2818/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2818/Pun/2025 निर्धारण वषा / Assessment Year : 2017-18 Pinnacle Contro & V Dcit, Ecohomes Pvt. Ltd., S Circle-4, Pune. Madhav Heritage, Tilak Road, Sadashiv Peth, Pune – 411030. Pan: Aaecp0400E Appellant/ Assessee Respondent /Revenue Assessee By Shri Suhas P. Bora Revenue By Shri Madhukar Anand-Jcit(Through Virtual) Date Of Hearing 07/01/2026 Date Of Pronouncement 08/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2017-18Dated 01.10.2025 Emanating From The Assessment Order Passed Under Section 147 Of The Act, Dated 27.08.2021. The Assessee Has Raised The Following Grounds Of Appeal : “1. Reassessment Bad In Law.

Section 143(3)Section 147Section 148Section 151Section 250Section 250(6)

this case, Assessee Company had filed Return of Income electronically for A.Y.2017-18 on 30.03.2018 declaring total income at Rs.19,18,387/-. Then, Assessee filed Revised Return of Income on 19.05.2018, declaring total income at Rs.19,18,387/-. Assessee’s case was selected for scrutiny. During the scrutiny proceedings, assessee filed ... filed its e-return of income for the AY 2017-18 on 30.03.2018 declaring the income at Rs. 19,18,387/ Subsequently, assessee filed revised return of income 19.05.2018 without charging total income. The scrutiny assessment u/s 143(3) of the Income-tax Act, 1961 (the Act) was completed

Deputy Commissioner of Income-Tax, Madurai vs. Sri Jayajothi and Company Private Limited, Rajapalayam

In the result, the appeal of the revenue is partly allowed

ITA 2131/CHNY/2025[2014-15]Status: DisposedITAT Chennai08 Jan 2026AY 2014-15

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Ms. R. Anitha, Addl. CITFor Respondent: Shri. V. Srikrishnan, CA

Section 143(1)(a)Section 143(3)Section 263

which included the long term capital loss) admitted in AY 2014-15 as unabsorbed depreciation in AY 2015- 16. Subsequently, the assessee has filed revised return of income on 12.12.2016 showing the correct long term capital loss brought forward (Rs.6,12,86,666/-) in the relevant schedule after making necessary

Shriram Finance Ltd., Chennai vs. PCIT, Chennai

ITA 2043/CHNY/2025[2022-23]Status: DisposedITAT Chennai08 Jan 2026AY 2022-23

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.2043/Chny/2025 िनधा"रण वष"/Assessment Year: 2022-23 Shriram Finance Limited, Vs. The Principal Commissioner Of [Since Shriram City Union Finance Income Tax – 3, Limited Amalgamated With Shriram Chennai. Transport Finance Co. Limited & Presently Known As Shriram Finance Limited], Sri Towers, Plot No. 14A, South Phase, Industrial Estate, Guindy, Chennai 600 032. [Pan:Aaacs7018R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri C.N. Bipin, Cit सुनवाई की तारीख/ Date Of Hearing : 15.10.2025 घोषणा की तारीख /Date Of Pronouncement : 08.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.05.2025 Passed By The Ld. Principal Commissioner Of Income Tax – 3, Chennai For The Assessment Year 2022-23 Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri R. Sivaraman, AdvocateFor Respondent: Shri C.N. Bipin, CIT

Section 143(3)Section 234DSection 263Section 36(1)(vii)Section 36(1)(viia)Section 4

that the assessee filed return of income for AY 2022-23 on 31.10.2022 declaring total income of ₹.1548,25,20,310/- and subsequently filed revised return on 31.12.2022 declaring total income of ₹.1548,25,12,670/-. The case was selected for scrutiny and assessment under section 143(3) r.w.s. 144B

ACIT, Corporate Circle 1(1), Chennai vs. Capgemini Technology Services India Limited (Formerly Future Soft Private Limited), Chennai

In the result, appeal filed by the Revenue is dismissed

ITA 420/CHNY/2024[2006-07]Status: DisposedITAT Chennai08 Jan 2026AY 2006-07

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.420/Chny/2024 िनधा"रण वष"/Assessment Year: 2006-07 V. The Acit, Capgemini Technology Corporate Circle-1(1), Services India Ltd., Block 3, ‘C’ Wing, 4Th Floor, Chennai. Capgemini Knowledge Park, Airoli Knowledge Park, Thane Belapur Road, Navi Mumbai- 400 708. [Pan: Aaacf 0482 E] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.S.P. ChidambaramFor Respondent: Ms.E. Pavuna Sundari, CIT

Section 10ASection 10A(2)Section 10A(5)Section 143(1)

filed on 31.10.2001, the assessee also annexed a note to the computation of income clearly stating as above. However, thereafter the assessee filed the revised return of income under Section 139(5) of the IT Act on 23.12.2002 and filed a declaration under Section 10B (8) which admittedly was after ... they are to be literally construed, more particularly in a case of exemption sought by an assessee. 9. In such a situation, filing a revised return under section 139(5) of the IT Act claiming carrying forward of losses subsequently would not help the assessee. In the present case

Red Hat India Private Limited, Mumbai vs. Principal Commissioner of Income Tax -6, Mumbai

ITA 3016/MUM/2025[2011-12]Status: DisposedITAT Mumbai08 Jan 2026AY 2011-12

Section 143(3)Section 147Section 148Section 263Section 92C

same had been reflected in the succeeding year. In order to offer such income in the correct year of accrual, the assessee filed a revised return voluntarily offering the royalty income to tax in the year under appeal. 4. During the original assessment proceedings, the Assessing Officer called for details ... section 148. The assessee objected to reopening, inter alia, on the ground that the royalty income had already been offered to tax through a revised return and examined earlier. The objections were rejected, and the Assessing Officer made a reference to the Transfer Pricing Officer under section 92CA. During

Income Tax Officer, Ward 2(1), Thane vs. Bherulal Chunnilal Jain, Thane

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

ITA 5039/MUM/2024[2009-10]Status: DisposedITAT Mumbai08 Jan 2026AY 2009-10

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm Income Tax Officer, Mr. Bherulal Chunnilal Jain, Ward 2(1), B 201, Jay Rajleela Chs Ltd., Room No.25, B Wing, Deepak Nagar, 90 Feet Road, Vs. Ashar It Park, Bhayander West, Wagle Estate, Maharashtra – 400 101 Thane – 400 604 Pan:Afnpj6760J (Appellant) : (Respondent)

For Respondent: Shri S. Srinivasu, CIT DR

Section 143(1)Section 143(3)Section 148Section 250Section 271(1)(c)Section 68

declaring total income at Rs.1,10,850/- and the same was processed u/s. 143(1) of the Act on 29.07.2010. The assessee filed his revised return of income dated 19.12.2011 declaring total income at Rs.1,62,560/-. The assessee’s case was reopened vide notice dated

Ghcl Limited, Ahmedabad vs. The Dy.CIT, Central Circle-1(2), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1643/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

For Appellant: Shri Tushar Hemani, Sr. AdvocateFor Respondent: Shri Prem Prakash Meena, CIT-DR

Section 115JSection 143(1)Section 153CSection 153DSection 154Section 250

loss and unabsorbed depreciation in the return filed u/s. 153C and no new claim could be made before the Assessing Officer except by filing revised return of income following the decision of Supreme Court in the case of Goetz India Ltd 284 ITR 323 (SC) and further if no claim

Intertek India Private Limited, New Delhi vs. Assistant Commissioner of Income Tax, Circle 10(1), Delhi, New Delhi

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

ITA 2904/DEL/2025[2017-18]Status: DisposedITAT Delhi07 Jan 2026AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

Section 143

raised by the assessee are allowed. 7. The Ground No. 9 raised by the assessee is seeking TDS credit as per the revised return of income. This matter requires factual verification and hence we direct the Learned AO to grant the TDS credit in accordance with law. Accordingly, the Ground

Intertek India Private Limited, New Delhi vs. Assistant Commissioner of Income Tax, Circle 10(1), Delhi, New Delhi

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

ITA 2903/DEL/2025[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

Section 143