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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

DCIT, Circle 4(2), New Delhi vs. Ms Bharti Telemedia Ltd, New Delhi

In the result, the appeals of the Assessee are allowed and appeals of the Revenue are dismissed

ITA 4868/DEL/2024[2016-17]Status: DisposedITAT Delhi12 Dec 2025AY 2016-17

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 35ASection 4

details of validity of the licence are tabulated as under. 7. For the relevant assessment year i.e. A.Y. 2020-21, the assessee filed its revised return of income on 31.03.2021 declaring total income of Rs.550,36,16,740/-. During the relevant year, the assessee incurred expenditure amounting to Rs.294

Srf Limited, Delhi vs. ACIT, Circle-10(1), Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 1449/DEL/2022[2018-19]Status: DisposedITAT Delhi12 Dec 2025AY 2018-19
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

been granted, and the total income has been taken from the intimation u/s 143(1) rather than the revised return filed on 29.03.2019. 7. All these are apparent computational errors verifiable from the record. Accordingly, we direct the AO to rectify the mistakes by eliminating the double disallowance under section ... granting the correct Chapter VI-A deduction and MAT credit, and adopting the income as per the revised return. The consequential demand u/s 156 shall be recomputed, and due refund, if any, shall be granted in accordance with law. These grounds are allowed for statistical purposes. 8. Apropos grounds nos.9

Srf Limited, New Delhi vs. ACIT, Circle-10(1), Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 1448/DEL/2022[2017-18]Status: DisposedITAT Delhi12 Dec 2025AY 2017-18
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

been granted, and the total income has been taken from the intimation u/s 143(1) rather than the revised return filed on 29.03.2019. 7. All these are apparent computational errors verifiable from the record. Accordingly, we direct the AO to rectify the mistakes by eliminating the double disallowance under section ... granting the correct Chapter VI-A deduction and MAT credit, and adopting the income as per the revised return. The consequential demand u/s 156 shall be recomputed, and due refund, if any, shall be granted in accordance with law. These grounds are allowed for statistical purposes. 8. Apropos grounds nos.9

Srf Limited, New Delhi vs. DCIT, Circle- 1, Ltu, New Delhi

In the result, the appeal being ITA No

ITA 4539/DEL/2017[2013-14]Status: DisposedITAT Delhi12 Dec 2025AY 2013-14

Bench: Shris.Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 10ASection 143(3)Section 144C(5)Section 14ASection 92BSection 92C

stated that assessee claimed TDS and TCS credit of Rs. 7,81,339/- and Rs. 29,269/- respectively in the revised return filed on 29.03.2013. However, the AO allowed credit of only Rs. 3,47,995/-, resulting in short credit of Rs. 4,62,613/-. The assessee filed rectification applications ... excluded from taxable income. 40. The AO as well as DRP did not entertain the claim of the assessee for the reason that no revised return was filed by the assessee claiming the aforesaid amount as capital receipts. They were of the view that the claim of the assessee cannot

Srf Ltd., New Delhi vs. ACIT, New Delhi

In the result, the appeal being ITA No

ITA 80/DEL/2016[2011-12]Status: DisposedITAT Delhi12 Dec 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 10ASection 143(3)Section 144C(5)Section 14ASection 92BSection 92C

stated that assessee claimed TDS and TCS credit of Rs. 7,81,339/- and Rs. 29,269/- respectively in the revised return filed on 29.03.2013. However, the AO allowed credit of only Rs. 3,47,995/-, resulting in short credit of Rs. 4,62,613/-. The assessee filed rectification applications ... excluded from taxable income. 40. The AO as well as DRP did not entertain the claim of the assessee for the reason that no revised return was filed by the assessee claiming the aforesaid amount as capital receipts. They were of the view that the claim of the assessee cannot

Vodafone West Limited, (Formerly Known As Vodafone Essar Gujarat Limited), Ahmedabad vs. The Dy.CIT, Circle-4(1)(2), Ahmedabad

In the result, the appeal by the Revenue is partly allowed for statistical\npurposes

ITA 671/AHD/2015[2010-11]Status: DisposedITAT Mumbai11 Dec 2025AY 2010-11
For Appellant: Shri K.K. VedFor Respondent: Shri Pankaj Kumar, CIT-DR
Section 142Section 143(2)Section 143(3)Section 144CSection 144C(5)Section 45Section 47Section 48

{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\n“J” BENCH, MUMBAI\nBEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER\nSHRI

The Dy CIT, Circle-4(1)(2), Ahmedabad vs. Vodafone West Limited, Ahmedabad

In the result, the appeal by the Revenue is partly allowed for statistical\npurposes

ITA 1634/AHD/2015[2010-11]Status: DisposedITAT Mumbai11 Dec 2025AY 2010-11
For Appellant: Shri K.K. VedFor Respondent: Shri Pankaj Kumar, CIT-DR
Section 142Section 143(2)Section 143(3)Section 144CSection 144C(5)Section 45Section 47Section 48

{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\n“J” BENCH, MUMBAI\nBEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER\nSHRI

DCIT, Circle- 19(1), New Delhi vs. Malvinder Mohan Singh, Delhi

In the result, appeal of the Revenue in ITA No

ITA 3029/DEL/2024[2017-18]Status: DisposedITAT Delhi10 Dec 2025AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Ms. Ankush Kalra, Sr. DR
Section 115BSection 139(1)Section 143(2)Section 64Section 69Section 90

Details of Income from outside India) and Schedule TY (Summary of tax relief claimed for taxes paid outside India) of original as well as revised return. Form 67 was also duly submitted under Acknowledgment No. 342138281221217 dated 22.12.2017 along with copy of return filed in Singapore and tax paid ... Mohan Singh section 139(4) of the Act for A.Y. 2017-18 was 31.03.2019 and the assessee filed form no. 67 on 22.12.2017 and revised return on 29.08.2018 which was within the prescribed time limit. Therefore, the form no. 67 is acceptable and no income to be taxed twice

Prabhnoor Singh, Bangalore vs. Income Tax Officer, Ward 6(1), Chandigarh

In the result, appeal of the assessee is allowed

ITA 904/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh09 Dec 2025AY 2021-22

Bench: Shri Laliet Kumar & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 904/Chd/2025 "नधा"रण वष" / Assessment Year: 2021-22 Prabhnoor Singh, Vs The Ito, B-408, Meda Heights, Ward 6(1), Bellandur, Doddakannelli Road, Chandigarh. Near Aet Circle, Bangalore. "थायी लेखा सं./Pan No: Dcjps5821M अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Ms. Preeti Goyal, Ca Revenue By : Dr. Ranjit Kaur, Addl. Cit, Sr.Dr Date Of Hearing : 08.12.2025 Date Of Pronouncement : 09.12.2025

For Appellant: Ms. Preeti Goyal, CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr.DR
Section 128Section 128(9)

return of income. It was submitted by the assessee that the assessee had filed the return of income on 31.07.2021 and thereafter filed the revised return of income on 31.03.2022 and alongwith the revised return of income, the assessee has filed Form 67 as contemplated u/s 128 of the Income ... have heard both the parties and perused the material available on record. Admittedly, in the present case, Form 67 was filed alongwith the revised return of income on 31.03.2022 within the permissible time limit as provided by the Act. The solitary ground for not according the benefit of the DTAA

Eris Lifesciences Limited, Ahmedabad vs. NFAC, Delhi (Present Jurisdiction- the Dy. CIT, Circle-2(1)(1)), Ahmedabad

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 915/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

indexation while computing book profit u/s 115JB. The AO rejected these claims on the ground that such relief could be claimed only through a revised return as per Goetze (India) Ltd. and CBDT Circular No. 549. Finally, the AO added the section 14A disallowance to book profit under section 115JB ... Assessing Officer during assessment proceedings, which the Assessing Officer rejected on the technical ground that such a claim could only be made through a revised return. The learned CIT(A) rightly admitted the claim following the ratio of NTPC Ltd. v. CIT (1998) 229 ITR 383 (SC), CIT v. Pruthvi

Eris Lifesciences Limited, Ahmedabad vs. NFAC, Dehi (Present Jurisdiction- the Dy. CIT, Circle-2(1)(1), Ahmedabad

Appeal are dismissed

ITA 914/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2021-22
For Appellant: Shri Vartik Choksi, ARFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

Assessing Officer during assessment proceedings, which\nthe Assessing Officer rejected on the technical ground that such a claim could\nonly be made through a revised return. The learned CIT(A) rightly admitted\nthe claim following the ratio of NTPC ... legitimate deductions. However, the Assessing\nOfficer rejected the claim solely on the ground that it constituted an\n\"additional claim\" not made through a revised return, relying on the decision\nof the Hon'ble Supreme Court in Goetze (India) Ltd. v. CIT, holding that the\nAssessing Officer has no power

Eris Lifesciences Limited, Ahmedabad vs. NFAC, Delhi (Present Jurisdiction - the Dy. CIT, Circle-2(1)(1)), Ahmedabad

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 913/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2020-21

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

indexation while computing book profit u/s 115JB. The AO rejected these claims on the ground that such relief could be claimed only through a revised return as per Goetze (India) Ltd. and CBDT Circular No. 549. Finally, the AO added the section 14A disallowance to book profit under section 115JB ... Assessing Officer during assessment proceedings, which the Assessing Officer rejected on the technical ground that such a claim could only be made through a revised return. The learned CIT(A) rightly admitted the claim following the ratio of NTPC Ltd. v. CIT (1998) 229 ITR 383 (SC), CIT v. Pruthvi

Eris Lifesciences Limited, Ahmedabad vs. NFAC, Dehi (Present Jurisdiction- the Dy.CIT, Circle-2(1)(1)), Ahmedabad

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 912/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

indexation while computing book profit u/s 115JB. The AO rejected these claims on the ground that such relief could be claimed only through a revised return as per Goetze (India) Ltd. and CBDT Circular No. 549. Finally, the AO added the section 14A disallowance to book profit under section 115JB ... Assessing Officer during assessment proceedings, which the Assessing Officer rejected on the technical ground that such a claim could only be made through a revised return. The learned CIT(A) rightly admitted the claim following the ratio of NTPC Ltd. v. CIT (1998) 229 ITR 383 (SC), CIT v. Pruthvi

DCIT Circle-2(1)(1), Ahmedabad, Vejalpur vs. Eris Lifesciences Limited Shivarth Ambit, Bodakdev Ahmedabad

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 850/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

indexation while computing book profit u/s 115JB. The AO rejected these claims on the ground that such relief could be claimed only through a revised return as per Goetze (India) Ltd. and CBDT Circular No. 549. Finally, the AO added the section 14A disallowance to book profit under section 115JB ... Assessing Officer during assessment proceedings, which the Assessing Officer rejected on the technical ground that such a claim could only be made through a revised return. The learned CIT(A) rightly admitted the claim following the ratio of NTPC Ltd. v. CIT (1998) 229 ITR 383 (SC), CIT v. Pruthvi

Dcie Circle-2(1)(1), Ahemdabad, Vejalpur vs. Eris Lifesciences Limited Shivarth Ambit, Bodakdev Ahmedabad

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 849/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2021-22

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

indexation while computing book profit u/s 115JB. The AO rejected these claims on the ground that such relief could be claimed only through a revised return as per Goetze (India) Ltd. and CBDT Circular No. 549. Finally, the AO added the section 14A disallowance to book profit under section 115JB ... Assessing Officer during assessment proceedings, which the Assessing Officer rejected on the technical ground that such a claim could only be made through a revised return. The learned CIT(A) rightly admitted the claim following the ratio of NTPC Ltd. v. CIT (1998) 229 ITR 383 (SC), CIT v. Pruthvi

DCIT Circle-2(1)(1), Ahmedabad vs. Eris Lifesciences Limited Shivarth Ambit, Bodakdev Ahmedabad

Appeal are dismissed

ITA 848/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2020-21
For Appellant: \nShri Vartik Choksi, ARFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

Assessing Officer during assessment proceedings, which\nthe Assessing Officer rejected on the technical ground that such a claim could\nonly be made through a revised return. The learned CIT(A) rightly admitted\nthe claim following the ratio of NTPC ... legitimate deductions. However, the Assessing\nOfficer rejected the claim solely on the ground that it constituted an\n\"additional claim\" not made through a revised return, relying on the decision\nof the Hon'ble Supreme Court in Goetze (India) Ltd. v. CIT, holding that the\nAssessing Officer has no power

DCIT, Circle-2(1)(1) Ahmedabad, Ahmedabad vs. Eris Lifescience Limited Shivarth Ambit, Ahmedabad

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 847/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

indexation while computing book profit u/s 115JB. The AO rejected these claims on the ground that such relief could be claimed only through a revised return as per Goetze (India) Ltd. and CBDT Circular No. 549. Finally, the AO added the section 14A disallowance to book profit under section 115JB ... Assessing Officer during assessment proceedings, which the Assessing Officer rejected on the technical ground that such a claim could only be made through a revised return. The learned CIT(A) rightly admitted the claim following the ratio of NTPC Ltd. v. CIT (1998) 229 ITR 383 (SC), CIT v. Pruthvi

Shri Multanchand Bora Trust, Pune vs. ACIT, Exemption, Circle- Aurangabad, Aurangabad

In the result, the Appeal of the assessee is partly allowed

ITA 1312/PUN/2025[2020-21]Status: DisposedITAT Pune09 Dec 2025AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1312/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Shri Multanchand Bora Trust, V The Assistant/Deputy 132B/2A, Ganeshkhind Road, S. Commissioner Of Income Pune – 411007. Tax, Exemption Circle, Aurangabad. Pan: Aafts3329F Appellant/ Assessee Respondent / Revenue Assessee By Shri Shrenik Gandhi Revenue By Shri Amit Bobde –Cit(Dr) Date Of Hearing 11/09/2025 Date Of Pronouncement 09/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Pune At Nashik Passed Under Section 263 Of The Income Tax Act, 1961 For A.Y.2020-21, Dated 30.03.2025 Emanating From Assessment Order U/S.143(3) Of The I.T.Act, Dated 20.09.2022. The Assessee Has Raised Following Grounds Of Appeal : “1. Ground No. 1: The Learned Cit (Exemption) Seriously Erred On The Facts & Law, In Exercising The Revisionary Powers Under Section

Section 143(3)Section 263Section 80G

theAssessing Officer ought to have proceeded with the matter as the assessee was following the cash system ofaccounting and the filing of the re-revised return, prima facie, indicated that the additional expenses claimedhad been incurred. In this regard, the following findings/reasons recorded by the learned C.I.T. in the orderdated ... claim regarding additional expenses was made through duly verified revised return.The claim was pressed during assessment proceedings carried on by A.O. after filing revised return and itwas specially stated in letter dated 13.02.2004 that expenses were for security purposes and that paymentshave been made out of cash balances available

M/S Gera Developments Pvt. Ltd, Pune vs. PCIT (Central), Pune

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

ITA 1053/PUN/2024[2020-21]Status: DisposedITAT Pune09 Dec 2025AY 2020-21

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Hari KrishanFor Respondent: Shri Amol Khairnar
Section 143(2)Section 143(3)Section 263

Assessing Officer 3. (a) Audited financial statements filed with original 17-59 return of income (b) Tax Audit Report 60-75 4. (a) Revised return of income filed on 31.03.2021 76-198 along with the following (b) Revised statement of income 199-217 5. Notice u/s.143(2) dated 29.06.2021 selecting

Shree Vikas Sharafi Sahkari Mandli Limited, Rajkot vs. PCIT-1 Rajkot, Rajkot

In the result, the appeal of the assessee is allowed

ITA 228/RJT/2025[2020-21]Status: DisposedITAT Rajkot08 Dec 2025AY 2020-21

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri Chetan Agarwal, Ld. A.RFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 147Section 2(19)Section 263Section 80(2)(f)Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(2)(f)

interest of revenue.” Shree Vikas Sharafi Sahkari Mandali Ltd. 3. Brief facts of the case are that the assessee has filed its revised return of income on 03/11/2020 for AY 2020-21 declaring NIL income. The assessee has claimed to be engaged in the business as credit society providing credit