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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

M/S. Yashaswi Fish Meal and Oil Company, Udupi vs. Deputy Commissioner of Income-Tax, Central Circle-1, Mangalore

In the result, all the appeals of the assessee are partly allowed

ITA 66/BANG/2023[2017-18]Status: DisposedITAT Bangalore01 Sept 2023AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shi V. Srinivasan, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 131Section 132(4)Section 133ASection 143Section 143(1)Section 143(3)Section 147Section 148

Rs.5,50,00,000 for the year 2016-17. Accordingly additional income of Rs.5,50,00,000 was offered to tax and revised Return of Income for the assessment year 2016-17 incorporating the additional income was filed on 31.03.2018 vide acknowledgement no. 598177411310318. This was also brought ... above, the ld. A.R. submitted that the additional income as agreed during the survey proceedings has been duly offered to tax in the revised return of income and there is no additional income to be assessed in the hands of assessee’s firm. 6.6 Thus, the ld. A.R. submitted that

M/S. Yashaswi Fish Meal and Oil Company, Udupi vs. Deputy Commissioner of Income-Tax, Central Circle-1, Mangalore

In the result, all the appeals of the assessee are partly allowed

ITA 65/BANG/2023[2015-16]Status: DisposedITAT Bangalore01 Sept 2023AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shi V. Srinivasan, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 131Section 132(4)Section 133ASection 143Section 143(1)Section 143(3)Section 147Section 148

Rs.5,50,00,000 for the year 2016-17. Accordingly additional income of Rs.5,50,00,000 was offered to tax and revised Return of Income for the assessment year 2016-17 incorporating the additional income was filed on 31.03.2018 vide acknowledgement no. 598177411310318. This was also brought ... above, the ld. A.R. submitted that the additional income as agreed during the survey proceedings has been duly offered to tax in the revised return of income and there is no additional income to be assessed in the hands of assessee’s firm. 6.6 Thus, the ld. A.R. submitted that

M/S. Yashaswi Fish Meal and Oil Company, Udupi vs. Deputy Commissioner of Income-Tax, Central Circle-1, Mangalore

In the result, all the appeals of the assessee are partly allowed

ITA 64/BANG/2023[2014-15]Status: DisposedITAT Bangalore01 Sept 2023AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shi V. Srinivasan, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 131Section 132(4)Section 133ASection 143Section 143(1)Section 143(3)Section 147Section 148

Rs.5,50,00,000 for the year 2016-17. Accordingly additional income of Rs.5,50,00,000 was offered to tax and revised Return of Income for the assessment year 2016-17 incorporating the additional income was filed on 31.03.2018 vide acknowledgement no. 598177411310318. This was also brought ... above, the ld. A.R. submitted that the additional income as agreed during the survey proceedings has been duly offered to tax in the revised return of income and there is no additional income to be assessed in the hands of assessee’s firm. 6.6 Thus, the ld. A.R. submitted that

M/S. Yashaswi Fish Meal and Oil Company, Udupi vs. Deputy Commissioner of Income-Tax, Central Circle-1, Mangalore

In the result, all the appeals of the assessee are partly allowed

ITA 63/BANG/2023[2013-14]Status: DisposedITAT Bangalore01 Sept 2023AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shi V. Srinivasan, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 131Section 132(4)Section 133ASection 143Section 143(1)Section 143(3)Section 147Section 148

Rs.5,50,00,000 for the year 2016-17. Accordingly additional income of Rs.5,50,00,000 was offered to tax and revised Return of Income for the assessment year 2016-17 incorporating the additional income was filed on 31.03.2018 vide acknowledgement no. 598177411310318. This was also brought ... above, the ld. A.R. submitted that the additional income as agreed during the survey proceedings has been duly offered to tax in the revised return of income and there is no additional income to be assessed in the hands of assessee’s firm. 6.6 Thus, the ld. A.R. submitted that

M/S. Yashaswi Fish Meal and Oil Company, Udupi vs. Deputy Commissioner of Income-Tax, Central Circle-1, Mangalore

In the result, all the appeals of the assessee are partly allowed

ITA 62/BANG/2023[2012-13]Status: DisposedITAT Bangalore01 Sept 2023AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shi V. Srinivasan, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 131Section 132(4)Section 133ASection 143Section 143(1)Section 143(3)Section 147Section 148

Rs.5,50,00,000 for the year 2016-17. Accordingly additional income of Rs.5,50,00,000 was offered to tax and revised Return of Income for the assessment year 2016-17 incorporating the additional income was filed on 31.03.2018 vide acknowledgement no. 598177411310318. This was also brought ... above, the ld. A.R. submitted that the additional income as agreed during the survey proceedings has been duly offered to tax in the revised return of income and there is no additional income to be assessed in the hands of assessee’s firm. 6.6 Thus, the ld. A.R. submitted that

M/S Sangam Souhard Credit Sahakari Limited, Bagalkot vs. DCIT, CPC, Bangalore

Appeals are ALLOWED

ITA 30/PAN/2023[2018-19]Status: DisposedITAT Panaji01 Sept 2023AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) आयकर अपऩल सं. / Ita No. 001/Pan/2023 निर्धारण वषा / Assessment Year : 2018-19 Shri Bhagyalaxmi Co-Operative Credit Society Ltd., Mallapur, Pg Main Rd., Ghataprabha, Karnataka-591306 Pan: Aaaas5624D . . . . . . . अपीलार्थी / Appellant बिधम / V/S Dy. Commissioner Of Income Tax, Cpc, Bengaluru . . . . . . . प्रत्यर्थी / Respondent & आयकर अपऩल सं. / Ita No. 030/Pan/2023 निर्धारण वषा / Assessment Year : 2018-19 M/S Sangam Souharda Credit Sahakari Ltd., A/P. Galgali, Taluka-Bilgi, Dist.-Bagalkot-587117 Pan: Aaeas3685G . . . . . . . अपीलार्थी / Appellant बिधम / V/S Dy. Commissioner Of Income Tax, Cpc, Bengaluru . . . . . . . प्रत्यर्थी / Respondent द्वधरध / Appearances Assessee By : Mr Sateesh Nadagouda For Ita No. 001& None For Ita No. 030 [‘Ld. Ar’] Revenue By : Mr N. Shrikanth [‘Ld. Dr’] सुनवाई की तारीख / Date Of Conclusive Hearing : 07/08/2023 घोषणा की तारीख / Date Of Pronouncement : 01/09/2023 आदेश / Order Per G. D. Padmahshali, Am; These Two Appeals Of Different Assessee Are Instituted U/S 253(1) Of Income-Tax Act, 1961 [‘The Act’ Hereafter] Against Respective Orders Passed U/S 250 Of The Act By National Faceless Appeal Centre, Delhi [‘Nfac’ Hereafter] For Assessment Year 2018-19 [‘Ay’ Hereinafter].

For Appellant: Mr Sateesh Nadagouda forFor Respondent: Mr N. Shrikanth [‘Ld. DR’]
Section 139(1)Section 143(1)Section 246(1)Section 250Section 253(1)Section 80ASection 80A(1)Section 80P

under; ITAT-Panaji Page 4 of 7 ITA No.001 & 030/PUN/2023 AY 2018-19 Belated Return-143(1)(a)(v) Original Return of Income Filed Revised Return of Income Filed Allowability of Allowability of After expiry of due After expiry of due Deduction u/c VI-A Deduction u/c VI-A Asst

Shri Bhagyalaxmi Co-Operative Credit Society Limited, Mallapur vs. Deputy Commissioner of Income Tax, CPC, Bangaluru

Appeals are ALLOWED

ITA 1/PAN/2023[2018-19]Status: DisposedITAT Panaji01 Sept 2023AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) आयकर अपऩल सं. / Ita No. 001/Pan/2023 निर्धारण वषा / Assessment Year : 2018-19 Shri Bhagyalaxmi Co-Operative Credit Society Ltd., Mallapur, Pg Main Rd., Ghataprabha, Karnataka-591306 Pan: Aaaas5624D . . . . . . . अपीलार्थी / Appellant बिधम / V/S Dy. Commissioner Of Income Tax, Cpc, Bengaluru . . . . . . . प्रत्यर्थी / Respondent & आयकर अपऩल सं. / Ita No. 030/Pan/2023 निर्धारण वषा / Assessment Year : 2018-19 M/S Sangam Souharda Credit Sahakari Ltd., A/P. Galgali, Taluka-Bilgi, Dist.-Bagalkot-587117 Pan: Aaeas3685G . . . . . . . अपीलार्थी / Appellant बिधम / V/S Dy. Commissioner Of Income Tax, Cpc, Bengaluru . . . . . . . प्रत्यर्थी / Respondent द्वधरध / Appearances Assessee By : Mr Sateesh Nadagouda For Ita No. 001& None For Ita No. 030 [‘Ld. Ar’] Revenue By : Mr N. Shrikanth [‘Ld. Dr’] सुनवाई की तारीख / Date Of Conclusive Hearing : 07/08/2023 घोषणा की तारीख / Date Of Pronouncement : 01/09/2023 आदेश / Order Per G. D. Padmahshali, Am; These Two Appeals Of Different Assessee Are Instituted U/S 253(1) Of Income-Tax Act, 1961 [‘The Act’ Hereafter] Against Respective Orders Passed U/S 250 Of The Act By National Faceless Appeal Centre, Delhi [‘Nfac’ Hereafter] For Assessment Year 2018-19 [‘Ay’ Hereinafter].

For Appellant: Mr Sateesh Nadagouda forFor Respondent: Mr N. Shrikanth [‘Ld. DR’]
Section 139(1)Section 143(1)Section 246(1)Section 250Section 253(1)Section 80ASection 80A(1)Section 80P

under; ITAT-Panaji Page 4 of 7 ITA No.001 & 030/PUN/2023 AY 2018-19 Belated Return-143(1)(a)(v) Original Return of Income Filed Revised Return of Income Filed Allowability of Allowability of After expiry of due After expiry of due Deduction u/c VI-A Deduction u/c VI-A Asst

Alok Ghosh, Kolkata vs. ITO, WD.28(4), Kolkata

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

ITA 711/KOL/2023[2016-17]Status: DisposedITAT Kolkata31 Aug 2023AY 2016-17

Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2016-17

For Appellant: Shri Rip Das, FCAFor Respondent: Ms. Monalisha Pal Mukherjee, JCIT
Section 139(1)Section 143(3)Section 250Section 48(2)Section 54

entitled to claim deduction u/s. 48 for the first time, during the course of assessment proceedings unless made by way of filing revised return u/s. 139(5) of the Act. He thus, held that since assessee has not filed any revised return for the purpose of claiming deduction of cost

Snj Distillers Pvt. Ltd..Company, Chennai vs. ACIT, Central Circle 3(2), Chennai

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

ITA 354/CHNY/2023[2013-14]Status: DisposedITAT Chennai31 Aug 2023AY 2013-14

Bench: Shri Manjunatha. G & Shri Manomohan Dasआयकर अपील सं./Ita No.354/Chny/2023 िनधा(रण वष( /Assessment Year: 2013-14 Snj Distillers Pvt. Ltd., The Asst. Commissioner Of No.72, Greams Road, Vs. Income Tax, Thousandlights, Central Circle-3(2), Chennai – 600 006. Chennai. [Pan: Aalcs-9312-F] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri M. Karunakaran, Advocate ""यथ" क" ओर से /Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई क" तारीख/Date Of Hearing : 01.08.2023 : 31.08.2023 घोषणा क" तारीख /Date Of Pronouncement आदेश / O R D E R

For Appellant: Shri M. Karunakaran, AdvocateFor Respondent: Shri D. Hema Bhupal, JCIT
Section 132B(3)

assessee had stated that the amount seized belong to the assessee. However, later on, Shri Bilash Khatiwada changed his stand and filed revised return of income claiming that the seized amount of Rs. 50,00,000/- was his income from other source. The learned AO of Shri Bilash Khatiwada ... Delhi accepted the revised return of income as filed by Shri Bilash Khatiwada. The learned CIT(A) finally disposed of the appeal in favour of the assessee. The Ld. CIT(A) directed the ld.AO to approach the PCIT, Guwahati, Assam for appropriation of the amount

M/S. Bharat Electronics Limited, Bangalore vs. Assistant Commissioner of Income Tax, Ltu, Circle-1, Bengaluru

In the result, appeal filed by the assessee is allowed

ITA 395/BANG/2023[2014-15]Status: DisposedITAT Bangalore31 Aug 2023AY 2014-15

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2014-15

For Appellant: Ms. Richa B, CAFor Respondent: Shri. Aseem Sharma, CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 143(3)Section 14ASection 250

Assessment Year 2014-15, the return of income was filed on 22.09.2014 admitting total income of Rs.8,44,17,38,820/-. Subsequently, assessee filed revised return of income on 01.03.2016 by declaring income of Rs.8,43,74,17,120/-. Assessment was selected for scrutiny and notice under section

Sachin Vilas Chaugule, Mumbai vs. CIT (Appeals)-47, Mumbai

In the result we set-aside all these 6

ITA 713/MUM/2023[2014-2015]Status: DisposedITAT Mumbai31 Aug 2023AY 2014-2015

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Mr. Vimal Punamiya, AdvFor Respondent: Dr. Kishor Dhule, CIT DR
Section 143Section 153ASection 251

year 2014 – 15 though before the settlement commission the income was spread over number of the years but before the assessing officer assessee filed revised return offering the income for assessment year 2014 – 15. The learned assessing officer made the addition for the income once as offered before settlement commission ... down under the income tax act. Therefore, most of the income was required to be offered in assessment year 14 – 15. As per the revised return filed by the assessee on 3/3/2016, he declared total income of ₹ 84,719,040. Total cash found during the search was offered as income

Sachin Vilas Chaugule, Mumbai vs. CIT (Appels), Mumbai

In the result we set-aside all these 6

ITA 712/MUM/2023[2013-2014]Status: DisposedITAT Mumbai31 Aug 2023AY 2013-2014

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Mr. Vimal Punamiya, AdvFor Respondent: Dr. Kishor Dhule, CIT DR
Section 143Section 153ASection 251

year 2014 – 15 though before the settlement commission the income was spread over number of the years but before the assessing officer assessee filed revised return offering the income for assessment year 2014 – 15. The learned assessing officer made the addition for the income once as offered before settlement commission ... down under the income tax act. Therefore, most of the income was required to be offered in assessment year 14 – 15. As per the revised return filed by the assessee on 3/3/2016, he declared total income of ₹ 84,719,040. Total cash found during the search was offered as income

Sachin Vilas Chaugule, Mumbai vs. CIT (Appeals), Mumbai

In the result we set-aside all these 6

ITA 711/MUM/2023[2012-13]Status: DisposedITAT Mumbai31 Aug 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Mr. Vimal Punamiya, AdvFor Respondent: Dr. Kishor Dhule, CIT DR
Section 143Section 153ASection 251

year 2014 – 15 though before the settlement commission the income was spread over number of the years but before the assessing officer assessee filed revised return offering the income for assessment year 2014 – 15. The learned assessing officer made the addition for the income once as offered before settlement commission ... down under the income tax act. Therefore, most of the income was required to be offered in assessment year 14 – 15. As per the revised return filed by the assessee on 3/3/2016, he declared total income of ₹ 84,719,040. Total cash found during the search was offered as income

Sachin Vilas Chaugule, Mumbai vs. CIT (Appeals), Mumbai

In the result we set-aside all these 6

ITA 710/MUM/2023[2011-12]Status: DisposedITAT Mumbai31 Aug 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Mr. Vimal Punamiya, AdvFor Respondent: Dr. Kishor Dhule, CIT DR
Section 143Section 153ASection 251

year 2014 – 15 though before the settlement commission the income was spread over number of the years but before the assessing officer assessee filed revised return offering the income for assessment year 2014 – 15. The learned assessing officer made the addition for the income once as offered before settlement commission ... down under the income tax act. Therefore, most of the income was required to be offered in assessment year 14 – 15. As per the revised return filed by the assessee on 3/3/2016, he declared total income of ₹ 84,719,040. Total cash found during the search was offered as income

Sachin Vilas Chaugule, Mumbai vs. CIT (Appeals), Mumbai

In the result we set-aside all these 6

ITA 709/MUM/2023[2010-2011]Status: DisposedITAT Mumbai31 Aug 2023AY 2010-2011

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Mr. Vimal Punamiya, AdvFor Respondent: Dr. Kishor Dhule, CIT DR
Section 143Section 153ASection 251

year 2014 – 15 though before the settlement commission the income was spread over number of the years but before the assessing officer assessee filed revised return offering the income for assessment year 2014 – 15. The learned assessing officer made the addition for the income once as offered before settlement commission ... down under the income tax act. Therefore, most of the income was required to be offered in assessment year 14 – 15. As per the revised return filed by the assessee on 3/3/2016, he declared total income of ₹ 84,719,040. Total cash found during the search was offered as income

Rahul Ranjit Bhat, Mumbai vs. Asstt. DIT CPC-Income Tax, Mumbai

In the result, appeal of the assessee is allowed

ITA 1340/MUM/2023[2020-2021]Status: DisposedITAT Mumbai31 Aug 2023AY 2020-2021

Bench: The Due Date Of Filing Return Of Income As Per Rule 128(9) Of The Income Tax Rules, 1962 In The Adjustment Made U/S.143(1).

Section 139(1)Section 143(1)Section 39(1)Section 90

claim the credit for US taxes as required under Rule 128 of the IT Rules amounting to Rs.11,22,862/-. Thereafter, assessee immediately filed revised return on 27/03/2021 and claimed credit for US taxes and filed Form 67 alongwith revised return. However, the CPC Bangalore vide order dated 16/12/2021 ... well as procuring certificate of taxes and due to this fact assessee could not submit form No.67 before the due date u/s.39(1). The revised return which was processed u/s. 143(1), the foreign tax relief was again denied on the ground that claim was belated and 3 Shri Rahul

M/S. Khadi Grammodhyog Pratisthan, Bikaner vs. ADIT, CPC / ITO, Ward-1(2), Bangaluru / Bikaner

In the result, appeal of the assessee is partly allowed

ITA 87/JODH/2023[2019-20]Status: DisposedITAT Jodhpur31 Aug 2023AY 2019-20
Section 139(1)Section 139(4)Section 143(1)Section 250(6)

That the order passed by the assessing officer is illegal against the law and judicial decorum. 2. The assessing officer should have accepted the revised return submitted by the assessee which was in accordance with the law and CIT(A) should have accepted the ground and should not rejected without ... legal proof. Honorable, please also look into the working style of the Income Tax Commissioner Appeal. The assessing officer should have accepted the revised return submitted by the assessee which was in accordance with the law and CIT (A) should have accepted the ground and should not be rejected without

Bombardier Transportation Signal (Thailand) Limited, Thailand vs. ACIT, Circle Int. Taxation 1(1)(2), New Delhi

In the result, three appeals of the assessee are partly allowed as indicated above

ITA 726/DEL/2023[2016-17]Status: DisposedITAT Delhi31 Aug 2023AY 2016-17

Bench: Shri Narendra Kumar Billaiya & Shri Challa Nagendra Prasad

For Appellant: Shri Anubhav Rastogi, &
Section 143(2)Section 143(3)Section 144CSection 144C(1)Section 263Section 90(2)

referred to as "assessee") e-filed its return of income on 29.11.2013 declaring total income of Rs.5,62,36,850/- The assessee filed a revised return on 31.03.2015 declaring Nil income. The case was selected for scrutiny under CASS and a notice u/s 143(2) of the Income Tax Act1961 ... provisions of the Act and India- Thailand DTAA. After considering replies and documents filed by the assessee its income as shown in the revised return of income is accepted. 3. Assessment is, accordingly made on Nil income. Credit for prepaid taxes is allowed after due verification. Detail of computation

J R Rice India Pvt. Ltd., Delhi vs. ACIT, Circle-13(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 2852/DEL/2022[2017-18]Status: DisposedITAT Delhi31 Aug 2023AY 2017-18

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganeshassessment Year: 2017-18 J.R. Rice India Pvt. Ltd., Vs Acit, 5593/94, Lahori Gate, Main Road, Circle-13(1), Naya Bazar, New Delhi. Delhi. Pan: Aaccj1734F (Appellants) (Respondent) Assessee By : Shri Suresh K. Gupta, Ca Revenue By : Shri Anuj Garg, Sr. Dr Date Of Hearing : 10.05.2023 Date Of Pronouncement : 31.07.2023 Order Per M. Balaganesh, Am: This Appeal In Ita No.2852/Del/2022 For Ay 2017-18 Arise Out Of The Order Of The National Faceless Appeal Centre (Nfac) (Hereinafter Referred To As The ‘Ld. Cit(A)’) Dated 30.11.2022 In Din & Order No.Itba/Nfac/S/250/2022- 23/1047739597(1) Against The Order Of Assessment Passed U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 27.12.2019 By The Assessing Officer, Circle-13(1), Delhi (Hereinafter Referred To As ‘Ld. Ao’). 2. The Only Effective Issue To Be Decided In This Appeal Is As To Whether The Ld.Cit(A) Was Justified In Confirming The Addition Made In The Sum Of Rs.52,60,000/- U/S 68 Of The Act R.W.S. 115Bbe Of The Act In Respect Of Cash Deposits Made During Demonetization Period, In The Facts & Circumstances Of The Instant Case.

For Appellant: Shri Suresh K. Gupta, CAFor Respondent: Shri Anuj Garg, Sr. DR
Section 143(3)Section 44ASection 68

processing of food grains. The assessee filed its original return of income on 12.07.2017 declaring total income of Rs.1,38,97,643/-. Later, a revised return was filed on 29.05.2018 showing the same total income of Rs.1,38,97,643/-. The ld. AO observed that the assessee had deposited specified

Bombardier Transportation Signal (Thailand ) Limited, Thailand vs. DCIT, Circle-1(1)(2) Int. Taxation, Delhi

In the result, three appeals of the assessee are partly allowed as indicated above

ITA 2193/DEL/2022[2019-20]Status: DisposedITAT Delhi31 Aug 2023AY 2019-20

Bench: Shri Narendra Kumar Billaiya & Shri Challa Nagendra Prasad

For Appellant: Shri Anubhav Rastogi, &
Section 143(2)Section 143(3)Section 144CSection 144C(1)Section 263Section 90(2)

referred to as "assessee") e-filed its return of income on 29.11.2013 declaring total income of Rs.5,62,36,850/- The assessee filed a revised return on 31.03.2015 declaring Nil income. The case was selected for scrutiny under CASS and a notice u/s 143(2) of the Income Tax Act1961 ... provisions of the Act and India- Thailand DTAA. After considering replies and documents filed by the assessee its income as shown in the revised return of income is accepted. 3. Assessment is, accordingly made on Nil income. Credit for prepaid taxes is allowed after due verification. Detail of computation