“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

Shot Formats Digital Productions Pvt Ltd, Mumbai vs. DCIT Circle 16(1), Mumbai

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

ITA 6879/MUM/2024[2013-14]Status: DisposedITAT Mumbai25 Nov 2025AY 2013-14

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2013-14

For Respondent: Mr. Dinesh Kureja a/w

Section 68

declaring total income of Rs. 7,62,78,710/-. Thereafter the assessee company had field r the assessee company had field revised return of income on evised return of income on 12.03.2015, declaring total income of Rs. 2,11,76,330/ 12.03.2015, declaring total income

Shri Swatantra Kumar Shukla, Kanpur vs. Deputy Commissioner of Income Tax-3, Kanpur

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

ITA 575/LKW/2019[2015-16]Status: DisposedITAT Lucknow24 Nov 2025AY 2015-16

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2015-16 Swatantra Kumar Shukla, Vs. Dy. Cit-3, Kanpur 61/139, Sita Ram Mohal, Kanpur- 208001 (U.P.) Pan: Acaps5484N (Appellant) (Respondent) Assessee By: Sh. P.K. Kapoor, C.A. Revenue By: Sh. R.R.N. Shukla, Addl Cit Dr Date Of Hearing: 03.09.2025 Date Of Pronouncement: 24.11.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A)- 1, Kanpur, Passed On 29.07.2019 Wherein The Appeal Of The Assessee Against The Orders Passed By The Assessing Officer Under Section 143(3) Of The Act For The A.Y. 2015-16 On 29.12.2017 Has Been Dismissed. The Grounds Of Appeal Are As Under: - “1. That The Ld Cit(A) Was Wrong In Confirming The Addition Of Rs. 1,39,81,850- Made By The Ao Without Any Valid Reason. 2. That The Revenue Was Wrong In Disallowing The Claim Of Long Term Capital Gains U/S 10(38) Of The Act & The Same Is Against Facts & Law. 3. That The Various Case Law Cited By The Revenue In Rejecting The Claim Is Wrong In As Much As The Facts Of The Appellant'S Case Are Distinguishable From The Cited Case Law. 4. That The Revenue Was Wrong In Invoking Section 68 Of The Act & The Same Is Not Justified & Unwarranted. 5. That It Was Wrong On The Part Of Revenue To Invoke Section 68 Of The Act In As Much As Initial Onus On The Assessee To Establish Identity, Credit Capacity Of The Creditor & Genuineness Of The Transaction Was Discharged. 6. That The Finding Of The Ld Ao That 'Long Term Capital Gains Of Rs.1 39,81,850/ Claimed By The Assessee Is Held To Have Been Arranged By The Assessee Through

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. R.R.N. Shukla, Addl CIT DR

Section 10(38)Section 143(3)Section 68

into white. He observed that many individuals had admitted to the fact of bogus claims of LTCG, STCG and withdrawn their claims by filing revised return and such confessions strengthened the case of the Revenue. In view of all these reasons, the ld. CIT(A) held that there ... into white. He also makes reference to other beneficiaries of the rigging scheme having withdrawn their claims of long term capital gains and filed revised return, but it is not clear as to whether the assessee has been confronted with these materials and granted opportunity to rebut the inferences drawn

Capgemini Technology Services India Limited ( Successor of Aricent Technologies Holdings Limited), Pune vs. Assistant Commissioner of Income Tax, Circle 1(1), Pune

In the result, the appeal of the assessee is allowed

ITA 1260/PUN/2025[2020-21]Status: DisposedITAT Pune24 Nov 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Vyomesh PathakFor Respondent: Shri Vidya Ratna Kishore

Section 143(3)Section 154Section 155(18)Section 270ASection 270A(2)Section 270A(6)(a)Section 270A(7)Section 270A(8)Section 270A(9)

letter together with the revised computation of income withdrawing the claim of deduction of the Health & education cess as expenses since the filing of revised return was barred by time, which fact has been duly noted and accepted in the Asessment Order. Therefore we also find merits in this contention

Usha Mohan, Bangalore vs. Income Tax Officer, Ward-3(2)(1), Bangalore

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

ITA 127/BANG/2025[2015-16]Status: DisposedITAT Bangalore24 Nov 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2015-16

For Appellant: Shri Zain Ahmed Khan, CA

Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 54

case of Goetz India Ltd. vs. CIT, the assessee can claim the said deduction only by filing a revised return within the time allowed. We are of the view that the above judgment relied on by the Ld.CIT(A) cannot be cited as precedent for the reason that

Ram Ratan Singh Pal, Lucknow vs. Assessing Officer, NFAC, Delhi

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

ITA 387/LKW/2025[2020-21]Status: DisposedITAT Lucknow21 Nov 2025AY 2020-21

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2020-21 Ram Ratan Singh Pal V. The Assessment Unit 5C/111, Girdhar Kunj Nfac Sector 5, Vrindavan Colony Telibagh, Lucknow (U.P) Tan/Pan:Ahqpp7018N (Appellant) (Respondent) Appellant By: Ms. Gurneet Kaur, Advocate Respondent By: Shri Amit Kumar, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 18.01.2024, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2020-21. 2.0 The Brief Facts Of The Case Are That The Assessee Filed His Return Of Income For The Year Under Consideration On 15.01.2021, Declaring A Total Income Of Rs.2,81,520/- Under The Head Income From Salary. The Return Filed By The Assessee Was Processed Under Section 143(1) Of The Income Tax Act, 1961 & A Refund Of Rs.2,50,510/- Was Created. Subsequently, The Assessee Filed Revised Return Of Income Under Section 139(5) Of The Act On 25.02.2021, Declaring The Same Income Originally Returned, I.E., Rs.2,81,520/-. In The Revised Return Of Income, The Assessee Declared Income From Salary At Rs.2,81,520/- & Income From

For Appellant: Ms. Gurneet Kaur, AdvocateFor Respondent: Shri Amit Kumar, D.R

Section 139(5)Section 143(1)Section 144Section 145(3)Section 270ASection 44A

processed under section 143(1) of the Income Tax Act, 1961 and a refund of Rs.2,50,510/- was created. Subsequently, the assessee filed revised return of income under section 139(5) of the Act on 25.02.2021, declaring the same income originally returned, i.e., Rs.2,81,520/-. In the revised ... declared income from salary at Rs.2,81,520/- and income from ITA No.387/LKW/2025 Page 2 of 8 business was shown as Nil. In the revised return of income, the assessee had shown sale of Rs.2,66,67,326/- and after claiming deduction on account of purchase at Rs.2

Varunendra Narayan Deekshit, Pune vs. CIT(A), Pune

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

ITA 988/PUN/2025[2020-21]Status: DisposedITAT Pune21 Nov 2025AY 2020-21

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Rajendra Agiwal

Section 10Section 139(5)Section 143(1)Section 154Section 154(3)

circumstances of the case and in law the Ld. ADIT, CPC has erred in passing rectification order u/s 154 of the Act against the revised return filed by the assessee on 31.03.2021 without granting any opportunity of being heard to the assessee. 4. On the facts and in the circumstances ... under the head ‘self assessment tax’ and accordingly the CPC reduced the demand and issued rectified intimation dated 18.03.2021. 4. Subsequently, the assessee filed revised return u/s 139(5) of the Act on 31.03.2021, wherein whole of the leave encashment of Rs.7,18,944/- was claimed as exemption

Discovery Digital Network Private Limited, Nashik vs. Assistant Commissioner of Income Tax, Circle 1, Nashik

ITA 2886/PUN/2024[2014-15]Status: DisposedITAT Pune21 Nov 2025AY 2014-15

For Appellant: \nShri Nimesh VoraFor Respondent: \nShri Vidya Ratan Kishore

Section 139(4)Section 143(3)Section 154Section 23Section 234DSection 244A

n01/12/2014 wherein claim of Advance Tax amounting to Rs.20,00,000/- was\nnot made and the time-limit for furnishing revised return as per the provisions of\nsection 139(4) expired on 31/03/2016 but the assessee had failed to make\nrevised return by claiming the aforesaid Advance Tax. Therefore, addition ... 244A might not be issued on the unclaimed refund beyond the expiry of time-\nperiod specified U/s 139(4) of the Act for furnishing revised Return of Income.\nWhereas, in assessee's case, interest U/s 244A of the Act had been granted to\nthe extent of Rs.4

Mahindra and Mahindra Financial Services Limited, Mumbai vs. Income Tax Department, Mumbai

In the result, ground no. 1 and 2 are remanded back to the Jurisdictional Assessing

ITA 5548/MUM/2025[2017-18]Status: DisposedITAT Mumbai21 Nov 2025AY 2017-18

Bench: Ms. Kavitha Rajagopal, Jm & Smt. Renu Jauhri, Am

For Respondent: Shri Ritesh Misra, CIT DR

Section 115Section 143(1)Section 143(2)Section 143(3)Section 234Section 250Section 68Section 80G

assessee had filed its return of income dated 30.11.2017, declaring total income at Rs. 1052,73,86,870/- and had filed its revised return of income dated 30.03.2019, declaring total income at Rs. ITA No. 5543 & 5548/Mum/2025 (A.Y. 2017-18) Mahindra & Mahindra Financial Services

Mahindra and Mahindra Financial Services Limted, Mumbai vs. Assistant Commissioner of Income Tax 7(2)(1), Mumbai

In the result, ground no. 1 and 2 are remanded back to the Jurisdictional Assessing

ITA 5543/MUM/2025[2017-18]Status: DisposedITAT Mumbai21 Nov 2025AY 2017-18

Bench: Ms. Kavitha Rajagopal, Jm & Smt. Renu Jauhri, Am

For Respondent: Shri Ritesh Misra, CIT DR

Section 115Section 143(1)Section 143(2)Section 143(3)Section 234Section 250Section 68Section 80G

DCIT 3.2.1, Mumbai vs. The New India Assurance Co Limited, Mumbai

ITA 2845/MUM/2024[2012-13]Status: DisposedITAT Mumbai21 Nov 2025AY 2012-13

Section 115JSection 143(3)Section 147Section 148

issuance of notice, dated 31/03/2017, under\nSection 148 of the Act. In response the Assessee, vide letter\ndated 17/04/2017, filed response stating that the revised return\nfiled on 24/03/2011 be treated as return filed in response to the\nnotice issued under Section 148 of the Act. A copy ... Assessee on 30/03/2017 which\nwas served on the Assessee on 31/03/2017. In response the\nAssessee vide letter, dated 17/04/2017, the Assessee submitted\nthat the revised return of income filed on 24/03/2011 declaring\nloss of INR.6,74,35,12,097/- may be treated as filed in response\nto the notice under

DCIT 3.2.1, Mumbai vs. The New India Assurance Co Limited, Mumbai

Accordingly, in terms of the aforesaid, Ground No. 3 to\n7 raised by the Assessee pertaining to merits of such\nadditions/disallowances are dismissed as having been rendered\ninfructuous

ITA 2841/MUM/2024[2014-15]Status: DisposedITAT Mumbai21 Nov 2025AY 2014-15

Section 115JSection 143(3)Section 147Section 148

DCIT 3.2.1, Mumbai vs. The New India Assurance Co Limited, Mumbai

ITA 2836/MUM/2024[2015-16]Status: DisposedITAT Mumbai21 Nov 2025AY 2015-16

Section 115JSection 143(3)Section 147Section 148

DCIT 3.2.1, Mumbai vs. The New India Assurance Co Limited, Mumbai

ITA 2834/MUM/2024[2016-17]Status: DisposedITAT Mumbai21 Nov 2025AY 2016-17

Section 115JSection 143(3)Section 147Section 148

issuance of notice, dated 31/03/2017, under Section 148 of the Act. In response the Assessee, vide letter dated 17/04/2017, filed response stating that the revised return filed on 24/03/2011 be treated as return filed in response to the notice issued under Section 148 of the Act. A copy ... Assessee on 30/03/2017 which was served on the Assessee on 31/03/2017. In response the Assessee vide letter, dated 17/04/2017, the Assessee submitted that the revised return of income filed on 24/03/2011 declaring loss of INR.6,74,35,12,097/- may be treated as filed in response to the notice under

DCIT 3.2.1, Mumbai vs. The New India Assurance Co Limited, Mumbai

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

ITA 2830/MUM/2024[2018-19]Status: DisposedITAT Mumbai21 Nov 2025AY 2018-19

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

For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal Kumar&

Section 115JSection 143(3)Section 147Section 148

DCIT 3.2.1, Mumbai vs. The New India Assurance Co Limited, Mumbai

ITA 2827/MUM/2024[2017-18]Status: DisposedITAT Mumbai21 Nov 2025AY 2017-18

For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal

Section 115JSection 143(3)Section 147Section 148

issuance of notice, dated 31/03/2017, under \nSection 148 of the Act. In response the Assessee, vide letter \ndated 17/04/2017, filed response stating that the revised return \nfiled on 24/03/2011 be treated as return filed in response to the \nnotice issued under Section 148 of the Act. A copy ... Assessee on 30/03/2017 which \nwas served on the Assessee on 31/03/2017. In response the \nAssessee vide letter, dated 17/04/2017, the Assessee submitted \nthat the revised return of income filed on 24/03/2011 declaring \nloss of INR.6,74,35,12,097/- may be treated as filed in response \nto the notice under

DCIT 3.2.1, Mumbai vs. The New India Assurance Co Limited, Mumbai

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

ITA 2823/MUM/2024[2019-20]Status: DisposedITAT Mumbai21 Nov 2025AY 2019-20

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

For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal Kumar&

Section 115JSection 143(3)Section 147Section 148

The New India Assurance Co. Ltd, Mumbai vs. Assistant Commissioner of Income Tax, Income Tax Officer, NFAC, Mumbai

Accordingly, in terms of the aforesaid, Ground No. 3 to\n7 raised by the Assessee pertaining to merits of such\nadditions/disallowances are dismissed as having been rendered\ninfructuous

ITA 2623/MUM/2024[2019-20]Status: DisposedITAT Mumbai21 Nov 2025AY 2019-20

Bench: "CLEAN_TEXT": "IN THE INCOME TAX APPELLATE TRIBUNAL\n\"I\" BENCH, MUMBAI\n\nSHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER\nSHRI RAHUL CHAUDHARY (Judicial Member)

Section 115JSection 143(3)Section 147Section 148

The New India Assurance Co Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle 3(2)(2), Mumbai

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

ITA 2622/MUM/2024[2018-19]Status: DisposedITAT Mumbai21 Nov 2025AY 2018-19

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

For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal Kumar&

Section 115JSection 143(3)Section 147Section 148

The New India Assurance Co. Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle-3(2)(2), Mumbai

ITA 2621/MUM/2024[2017-18]Status: DisposedITAT Mumbai21 Nov 2025AY 2017-18

Section 115JSection 143(3)Section 147Section 148

issuance of notice, dated 31/03/2017, under \nSection 148 of the Act. In response the Assessee, vide letter \ndated 17/04/2017, filed response stating that the revised return \nfiled on 24/03/2011 be treated as return filed in response to the \nnotice issued under Section 148 of the Act. A copy ... Assessee on 30/03/2017 which \nwas served on the Assessee on 31/03/2017. In response the \nAssessee vide letter, dated 17/04/2017, the Assessee submitted \nthat the revised return of income filed on 24/03/2011 declaring \nloss of INR.6,74,35,12,097/- may be treated as filed in response \nto the notice under

The New India Assurance Co. Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle-3(2)(2), Mumbai

ITA 2620/MUM/2024[2016-17]Status: DisposedITAT Mumbai21 Nov 2025AY 2016-17

Section 115JSection 143(3)Section 147Section 148