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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.

Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal
241 ITR 124 · 2000 · High Court
89
citing judgments

A penalty for concealment of income cannot be levied if an assessee files a revised return to buy peace and avoid litigation, and the revenue accepts this without objection.

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.

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

Ketan Harilal Mehta HUF by Its Karta Ketan H Mehta, Mumbai vs. ITO Ward-33(2)(2) Mumbai Presently Juridiction With ITO 42(1)(1) Mumbai, Mumbai

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

ITA 770/MUM/2023[2014-15]Status: DisposedITAT Mumbai03 Jun 2024AY 2014-15

Bench: Shri B R Baskaran & Shri Pavan Kumar Gadaleketan Harilal Mehta Huf Vs. Ito-42(1)(1), (By Its Karta Kautilya Bhavan, Ketanmehta)No.B/1101, Bkc,Bandra(E), Siddhi Vinayak Tower, Mumbai-400051. Opp Phoenix Hospital, Chikuwadi, Mumbai-400092. Pan/Gir No. : Aaehk3266N Appellant .. Respondent Appellant By : Shri. Nishit Gandhi.Ar Respondent By : Shri. P.D. Chougule.Sr.Dr Date Of Hearing 02.04.2024 Date Of Pronouncement 03.06.2024 आदेश / O R D E R Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac)(Cit(A)) Delhi Passed U/Sec 143(3) & U/Sec250 Of The Income Tax Act. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri. Nishit Gandhi.ARFor Respondent: Shri. P.D. Chougule.Sr.DR
Section 10(38)Section 68Section 69C

long long term securities (Illustrations) - Assessment year 2014-15 Assessee filed its return for relevant year - Subsequently, pursuant to a survey assessee filed revised return and claimed exemption in respect of long-term capital gains on shares under section 10(38) - Assessing Officer rejected assessee's plea and made additions

Commissioner of Income Tax vs. M/S Jamnalal Bajaj Foundation

ITA/808/2017HC Delhi31 May 2024

Bench: HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV,HON'BLE MR. JUSTICE YASHWANT VARMA

Section 11Section 11(1)Section 11(2)Section 11(3)(c)Section 12ASection 142(1)Section 143(1)Section 143(2)

scrutiny assessment under the Action Plan Guidelines. Statutory notice u/s 143(2) dated 17.09.2010 was issued to regularize the assessment proceeding. On 24.03.2011 Revised Return was filed with fresh computation of income along with reasons of the same. This Return was also selected for scrutiny under CASS and accordingly notice ... claimed exemption under section 11/12 of Income Tax Act. The assessee gave the following reasons for filing revised return as under: - "1. The Return of Income for the above year was filed on 30.09.2009 vide Acknowledgement No. 0000003032. The total income declares in the said Return of Income

Commissioner of Income Tax vs. M/S Jamnalal Bajaj Foundation

ITA-808/2017HC Delhi31 May 2024
Section 11Section 11(1)Section 11(2)Section 11(3)(c)Section 12ASection 142(1)Section 143(1)Section 143(2)

scrutiny assessment under the Action Plan Guidelines. Statutory notice u/s 143(2) dated 17.09.2010 was issued to regularize the assessment proceeding. On 24.03.2011 Revised Return was filed with fresh computation of income along with reasons of the same. This Return was also selected for scrutiny under CASS and accordingly notice ... claimed exemption under section 11/12 of Income Tax Act. The assessee gave the following reasons for filing revised return as under: - "1. The Return of Income for the above year was filed on 30.09.2009 vide Acknowledgement No. 0000003032. The total income declares in the said Return of Income

Sainath Educational Society, Guntur vs. The Income Tax Officer, Exemption Ward, Guntur

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

ITA 110/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam31 May 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.110/Viz/2024 (ननधधारण वर्ा / Assessment Year : 2017-18) Sainath Educational Society Vs. Income Tax Officer D.No.4-856/D, Perecherla (Exemption Ward) 4Th Lane, L N S Colony Guntur Medikonduru Md, Guntur [Pan : Aafas4764B] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Dr.Aparna Villuri, DR
Section 12ASection 143(1)Section 143(3)Section 270Section 270ASection 274

claimed revenue expenses to the tune of Rs.1,22,03,023/- and capital expenditure of Rs.36,20,859/-. The assessee filed a revised return on 24.11.2018 which was processed u/s.143(1) of the Act. The case was selected for scrutiny under “Manual – compulsory category scrutiny” as per the CBDT Instruction

ACIT, Chennai vs. Johnson Lifts Pvt. Ltd., Chennai

In the result the appeal is partly allowed

ITA 47/CHNY/2024[2016-17]Status: DisposedITAT Chennai31 May 2024AY 2016-17

Bench: Shri Aby T. Varkey, Jm & Shri Amitabh Shuklaआयकर अपील सं./Ita No.47/Chny/2024 & Ita No.48/Chny/2024 निर्धारण वर्ा /Assessment Year: 2016-17 & 2017-18

For Appellant: Shri R.Vijayaraghavan, AdvocateFor Respondent: Shri P.Sajit Kumar, JCIT
Section 32Section 36(1)(vii)Section 40Section 9

filed the Original return of income for the ITA No.47/Chny/2024 & ITA No.48/Chny/2024 :- 6 -: assessment year 2016-17 on 19.11:2016, and subsequently filed the revised return on 31.03,2018 declaring total income of Rs. 198,45,58,120. The tax payable thereon was computed at Rs.69,41,86, 901 which

Maya Kapoor, Gurgaon vs. Income Tax Officer, Ward-2(4), Gurgaon

The appeal of the assessee is allowed

ITA 783/DEL/2024[2021-22]Status: DisposedITAT Delhi31 May 2024AY 2021-22

Bench: Shri S Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri Rakesh Gupta, Adv. and Shri Deepesh Garg, AdvFor Respondent: Shri Om Parkash, Sr. Dr
Section 139Section 143(1)Section 154Section 90

delay in filing Form 67. It is an admitted position that the assessee filed Form 67 on 26-3-2021 alongwith the revised return before the end of the relevant AY 2020-21 which is in conformity with the CBDT notification No. 100/2022 amending Sub Rule 9 of Rule ... 302/MUM/2023 “10. Considered the rival submissions and material placed on record, we observe that assessee has filed Form-67 by filing revised return of income and not at the time of original return of income. In this regard the Coordinate Bench has considered the similar issue in the case

Flowserve Pte Ltd, Singapore vs. ACIT, Circle Int. Taxation 1(3)(1), New Delhi

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

ITA 1044/DEL/2023[2019-20]Status: DisposedITAT Delhi31 May 2024AY 2019-20

Bench: the CIT(A).

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri S.N. Pandey, Sr. DR
Section 195

with held tax u/s. 195 of the Act. The assessee filed return of income for impugned assessment year on 30.11.2019, thereafter the assessee filed revised return of income offering an amount of Rs. 32,95,798/- as tax on fees received towards quality development and training services that make available

Crystal Corp Protection Ltd., Delhi vs. DCIT, Circle- 6(2), New Delhi

In the result, appeal is partly allowed

ITA 7021/DEL/2019[2016-17]Status: DisposedITAT Delhi31 May 2024AY 2016-17

Bench: Shri Saktijit Dey & Shri Naveen Chandraassessment Year: 2016-17

Section 43B

However, the Assessing Officer rejected assessee’s claim stating that such claim having not been made through a revised return of income cannot be accepted. Assessee contested the disallowance before learned First Appellate Authority. While deciding the issue, learned First Appellate Authority sustained the disallowance on the reasoning that

ACIT, Circle - 19(1), New Delhi vs. Redkite Capital P. Ltd., New Delhi

The appeal of the Revenue is dismissed

ITA 6742/DEL/2018[2012-13]Status: DisposedITAT Delhi31 May 2024AY 2012-13

Bench: SHRI G.S. PANNU, HON'BLE (Vice President), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Shri M.P. Rastogi, CAFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 142(1)Section 143(2)Section 153C

banking financial company carrying on the financial business during the year under consideration and the AO had examined the fact that in the revised return, the assessee had shown an investment of Rs.1,30,00,000/- in debentures of M/s V. Hotels Ltd., but, no interest income for the same

Uttam Energy Limited, Pune vs. ACIT Circle-12, Pune

Appeal of the Assessee is partly allowed

ITA 2033/PUN/2019[2015-16]Status: DisposedITAT Pune30 May 2024AY 2015-16

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2033/Pun/2019 िनधा"रण वष" / Assessment Year: 2015-16 Uttam Energy Limited, The Acit, Circle-12, Mahendra Chamber, Mayfair V Pune. Co-Op Housing Society, S A-4, Dhole Patil Road, Pune – 411001. Pan: Aabcu4100H Appellant/ Revenue Respondent /Assessee Assessee By Shri Ch Naniwadekar & Kiran Sanmane – Ar;S Revenue By Shri Deepak Garg – Cit Date Of Hearing 16/05/2024 Date Of Pronouncement 30/05/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Has Been Filed By The Assessee Against The Final Assessment Order Of The Learned Acit, Circle-12, Pune Passed U/Sec. 143(3) R.W.S. 144C(13) Of The Of The Income Tax Act, 1961 (In Short "The Act") After Giving Effect To The Learned Drp’S Order Dated 24.09.2019. 1.1 The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 153Section 153(1)Section 40A(2)(b)Section 92BSection 92C

perused the records. In this case certain admitted basic facts are as under : Date Date of filling Return of Income 30/09/2015 Date of filling revised return 26/03/2016 Date of issue of Notice u/s 143(2) 18/03/2016 Date of Amendment Omitting Specified Domestic 01/04/2017 Transaction u/s.92BA(i) Date of Reference

Jesudason Biji, Chennai vs. Office of Income Tax Officer Int. Taxn Ward1(1), Chennai

In the result, appeal filed by the assessee is allowed

ITA 567/CHNY/2024[2014-15]Status: DisposedITAT Chennai30 May 2024AY 2014-15

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

For Appellant: Shri M.V.Swaroop, AdvocateFor Respondent: Shri D. Hema Bhupal, JCIT
Section 119(2)(b)Section 139(1)Section 139(5)Section 147Section 148Section 148ASection 149Section 54ESection 54F

original return of income (ROI) for A.Y. 2014-15 on 24.09.2014 admitting a total income of Rs. 33,64,415/-. Therefore, he filed a revised return on 31.03.2015 on the ground that the claim of deduction u/s.54EC consequent to investment of Rs.50,00,000/- was omitted to be claimed. According ... since, the original ROI was filed beyond the time limit prescribed u/s.139(1) of the Act, the revised return was held to be invalid as per sec.139(5) and was not acted upon. Pursuant to that the assessee preferred a petition before the CBDT for condonation of delay in filing

Prem Chand Agrawal, Tonk vs. Income Tax Officer, Tonk

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

ITA 7/JPR/2024[2011-12]Status: DisposedITAT Jaipur30 May 2024AY 2011-12

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Dinesh Kumar, AdvFor Respondent: Sh. Monisha Choudhary (Addl.CIT)
Section 139(4)Section 143(1)Section 154

case, the learned CIT(Appeals) is justified in not appreciating that it is a case of filing of corrected return rather a case of revised return? 6. That the appellant craves leave to add, amend or alter all or any of grounds of appeal and relief claimed before ... India) Ltd. V. Commissioner of Income Tax that assessee cannot amend return filed by him for claiming deduction or other than by filing a revised return. In this case Assessee has not filed any revised return for the relief, he is claiming. Accordingly, assessess's case has been dismissed

Prashanth Baburao Kulkarni, Bengaluru vs. Income Tax Officer, Ward-2, Gulbarga

In the result, the appeal is allowed for statistical purposes

ITA 321/BANG/2024[2015-16]Status: DisposedITAT Bangalore30 May 2024AY 2015-16

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2015-16

For Appellant: Shri Shreehari Kutsa, AdvocateFor Respondent: Shri Ganesh R. Ghale, Standing Counsel
Section 119(2)(b)Section 139(1)Section 192(1)Section 90

which foreign tax credit of Rs.65,972 was not claimed. Later on, immediately on the same day on 12.11.2016 he filed revised return of income and claimed foreign tax credit. The CPC processed the revised return on 26.02.2018 disallowing foreign tax credit. The assessee also filed return of income

Suresh Trambak Dusane, Nashik vs. ITO Ward 2(1), Nashik

In the result, all the three appeals filed by the assessee are dismissed

ITA 1431/PUN/2023[2018-19]Status: DisposedITAT Pune29 May 2024AY 2018-19

Bench: Shri Inturi Rama Rao & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.1429 To 1431/Pun/2023 "नधा"रण वष" Assessment Years : 2016-17, 2017-18 & 2018-19

For Respondent: Shri RY. Balawade
Section 139(1)Section 148Section 270ASection 271(1)(c)

filed on 18.07.2016 declaring total income of Rs.5,85,060/- after claiming deduction of Rs.1,36,517/-. Subsequently, the appellant filed revised Return of Income disclosing income of Rs.2,84,040/- after claiming deduction of Rs.2,74,000/-. The Assessing Officer, on receipt of information that the appellant made bogus ... believed one Mr. Kishor Patil, Tax Consultant who used to file the income-tax returns. Mr. Kishor Patil manipulated the information and filed the revised return without taking his consent. However, the rejecting the above contentions of the appellant the AO levied penalty of Rs.63,452/-. 3. Being aggrieved

Suresh Trambak Dusane, Nashik vs. ITO Ward 2(1), Nashik

In the result, all the three appeals filed by the assessee are dismissed

ITA 1430/PUN/2023[17-18]Status: DisposedITAT Pune29 May 2024

Bench: Shri Inturi Rama Rao & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.1429 To 1431/Pun/2023 "नधा"रण वष" Assessment Years : 2016-17, 2017-18 & 2018-19

For Respondent: Shri RY. Balawade
Section 139(1)Section 148Section 270ASection 271(1)(c)

filed on 18.07.2016 declaring total income of Rs.5,85,060/- after claiming deduction of Rs.1,36,517/-. Subsequently, the appellant filed revised Return of Income disclosing income of Rs.2,84,040/- after claiming deduction of Rs.2,74,000/-. The Assessing Officer, on receipt of information that the appellant made bogus ... believed one Mr. Kishor Patil, Tax Consultant who used to file the income-tax returns. Mr. Kishor Patil manipulated the information and filed the revised return without taking his consent. However, the rejecting the above contentions of the appellant the AO levied penalty of Rs.63,452/-. 3. Being aggrieved

Suresh Trambak Dusane, Nashik vs. ITO Ward 2(1), Nashik

In the result, all the three appeals filed by the assessee are dismissed

ITA 1429/PUN/2023[2016-17]Status: DisposedITAT Pune29 May 2024AY 2016-17

Bench: Shri Inturi Rama Rao & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.1429 To 1431/Pun/2023 "नधा"रण वष" Assessment Years : 2016-17, 2017-18 & 2018-19

For Respondent: Shri RY. Balawade
Section 139(1)Section 148Section 270ASection 271(1)(c)

filed on 18.07.2016 declaring total income of Rs.5,85,060/- after claiming deduction of Rs.1,36,517/-. Subsequently, the appellant filed revised Return of Income disclosing income of Rs.2,84,040/- after claiming deduction of Rs.2,74,000/-. The Assessing Officer, on receipt of information that the appellant made bogus ... believed one Mr. Kishor Patil, Tax Consultant who used to file the income-tax returns. Mr. Kishor Patil manipulated the information and filed the revised return without taking his consent. However, the rejecting the above contentions of the appellant the AO levied penalty of Rs.63,452/-. 3. Being aggrieved

ACIT, Corporate Circle-3(1), Chennai vs. M/S Tvs Motor Company Limited, Chennai

In the result the appeal of the Revenue is dismissed

ITA 6/CHNY/2023[2016-17]Status: DisposedITAT Chennai29 May 2024AY 2016-17

Bench: Shri Mahavir Singh & Shri Amitabh Shuklaआयकर अपील िं./Ita No. 06/Chny/2023 निर्धारण वर्ा /Assessment Year: 2016-17. The Asst. Commissioner Of M/S. Tvs Motor Company Ltd., Income Tax, Vs. Chaitanya, No.12, Corporate Circle-3(1), Khader Nawaz Khan Road, Chennai. Nungambakkam, Chennai – 600 006. [Pan: Aaacs7032B] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलधर्थी की ओर से/ Assessee By : Shri Vikaram Vijayaraghavan, Advocate प्रत्यर्थी की ओर से /Revenue By : Shri A. Sasikumar, Cit ुनवाई की तारीख/Date Of Hearing : 01.05.2024 घोषणा की तारीख /Date Of Pronouncement : 29.05.2024 आदेश / O R D E R

For Appellant: Shri Vikaram VijayaraghavanFor Respondent: Shri A. Sasikumar, CIT
Section 12Section 153(1)Section 250(6)Section 9Section 92C

auto parts. Return of income was filed by the assesse on 13.11.2016 declaring a total income of Rs.288, 25,43,130/- including a revised return declaring income of Rs.289,78,02,600/-. As the assesse had declared international transactions a reference was made by the AO u/s 92CA

Deputy Commissioner of Income Tax, Circle-4(1)(1), Bangalore vs. Mitsubishi Heavy Industries-Vst Diesel Engines Private Limited, Mysuru

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

ITA 505/BANG/2024[2016-17]Status: DisposedITAT Bangalore29 May 2024AY 2016-17

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2016-17

For Appellant: Shri Ankith, CA
Section 139Section 142(1)Section 143(2)Section 143(3)Section 250Section 271(1)(c)

AAFCM1573L filed the return of income for A.Y 2016-17 on 30.11.2016 declaring total income of Rs.81,53,230/-. Subsequently, the Assessee filed its revised return of income on 25.05.2017 declaring total income of Rs.4,87,96,230/- and paid the taxes as per the provisions of the Income ... receipt of Rectification order and MAP Orders for AY 2009-10 and AY 2011- 12 in the month of December 2016, assessee filed a revised return on 25.05.2017 for AY 16-17 as there was a change in the income tax loss carried forward for set off in subsequent years

Balasubramanyan Ashok, Bangalore vs. Deputy Commissioner of Income Tax, Circle-3(3)(1), Bangalore

In the result appeals filed by assessee stands allowed for statistical purposes

ITA 408/BANG/2024[2021-22]Status: DisposedITAT Bangalore29 May 2024AY 2021-22

Bench: Smt Beena Pillai & Shri Laxmi Prasad Sahu

For Appellant: Smt. Vaidehi .G, CA &For Respondent: Smt. Shamala .D.D, Addl. CIT (DR)
Section 139(5)Section 143(1)Section 154Section 6Section 90

arbitrarily denying the appellant's eligible claim amounting to INR 1,09,59,576 made in the revised return as per the provisions of the Section 90 of the Act read with Article 25(2)(a) of the India-US Double Taxation Avoidance Agreement, without providing any cogent reasons against ... 31/03/2020, 31/03/2021 and 31/01/2022 respectively for the years under consideration wherein, the FCT was claimed and Form 67 was filed along with the revised return. The assessee claimed a Foreign Tax Credit (FTC), under Article 23 of India-US Double Taxation Avoidance Agreement (DTAA). It is submitted that

Vaibhav Singhal, Bangalore vs. ITO Ward 3(3)(5), Saharanpur

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

ITA 3585/DEL/2023[2018-19]Status: DisposedITAT Delhi29 May 2024AY 2018-19

Bench: Shri Shamim Yahya & Shri Sudhir Pareekvaibhav Singhal, Vs. Ito, Ward 3(3)(5), 102, Golden Paradise, Saharanpur. 2Nd Cross Street, Hennur Bande Bus Stop, Bangalore – 560 043 (Karnataka). (Pan : Dawps9391K) (Appellant) (Respondent) Assessee By : Shri S.P. Chitambram, Advocate Revenue By : Shri Amit Katoch, Sr. Dr Date Of Hearing : 07.05.2024 Date Of Order : 29.05.2024 Order Per Shamim Yahya: This Appeal By The Assessee Is Directed Against The Order Of The Ld. Cit (Appeals)/National Faceless Appeal Centre (Nfac) Dated 12.10.2023 For The Assessment Year 2018-19. 2. Grounds Of Appeal Taken By The Assessee Read As Under :- “1. The Appellants Objects To The Order Dated 12 October 2023 Under Section 250 Of The Income Tax Act, 1961 (‘Act’) Issued By The Commissioner Of Income- Tax (Appeals), National Faceless Appeal Centre (Nfac) For The Aforesaid Assessment Year On The Following Grounds: 2. Denial Or Claim Of Foreign Tax Credit U/S 90 Of The Act

For Appellant: Shri S.P. Chitambram, AdvocateFor Respondent: Shri Amit Katoch, Sr. DR
Section 139Section 139(1)Section 143(1)Section 143(2)Section 143(3)Section 234CSection 250Section 90

credit as per the Double Taxation Avoidance Agreement (‘DTAA’) between India and the host jurisdiction even if a Form 67 is filed along with revised return of income. 2.4 The learned CIT (A) has failed to understand the fact that Rule 128 nowhere provides that if the Form ... Rs.5,86,619/- was claimed on estimate basis as US return was not available. The same was corrected to Rs.6,67,530/- in the revised return as US return was available. The appellant also revised Form 67 accordingly. 5.1 It is also explained and noted that the intimation