“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

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

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

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 7(1), Mumbai vs. Sandoz P.Ltd, Mumbai

In the result, the appeals by the assessee for assessment years 2005-06

ITA 3733/MUM/2013[2006-07]Status: DisposedITAT Mumbai09 Dec 2022AY 2006-07

Bench: Shri M. Balaganesh & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Prakash Mane

Section 120(4)(b)Section 127Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250

processed and intimation under section 143(1) was issued on 23/01/2007 by the ACIT, Circle–7(1) Mumbai. Thereafter, the assessee filed its revised return of income on 30/03/2007 with the ACIT, Circle–7(1) Mumbai. Subsequently, notice under section 143(2) of the Act along with a questionnaire ... dated 13/10/2021, having 9 pages, was filed for the assessment year 2006–07, wherein the copy of the acknowledgment of return of income and revised return of income filed with DCIT, Circle-7(1), Mumbai is placed on record. From the said factual paper book, we find that

Raj Kumar Jain, Jaipur vs. Assistant Commissioner of Income Tax, Central Circle – 2, Jaipur

In the result, appeal of the assessee is allowed

ITA 323/JPR/2022[2014-15]Status: DisposedITAT Jaipur08 Dec 2022AY 2014-15

For Appellant: Shri S.L. Poddar (Advocate)For Respondent: Shri P.R. Meena (CIT)

Section 132Section 132(4)Section 133ASection 139(1)Section 143(3)Section 153B(1)(b)Section 271Section 271ASection 271aSection 274

case the Hon'ble ITAT has deleted penalty of Rs. 50,77,800/- levied u/s 271(1)(c) on the ground that in the revised return surrender was made to buy peace. Further held that mere surrendering the additional amount does not amount to concealed income or inaccurate particular

Pannalal Shivratan Bagdia, Jalna vs. Deputy Commissioner of Income-Tax, Jalna

In the result, Ground No.2 raised by the Assessee is Dismissed

ITA 1211/PUN/2017[2012-13]Status: DisposedITAT Pune08 Dec 2022AY 2012-13

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1211/Pun/2017 िनधा"रण वष" / Assessment Year : 2012-13 Pannalal Shivratan Bagadia, The Deputy Commissioner Bagadia Palace, Rajendra Prasad V Of Income-Tax, Jalna Road, Jalna – 431203. S Circle, Jalna. Pan: Aaqpb 9753 M Appellant/ Assessee Respondent /Revenue Assessee By Shri Abhay Agrawal – Adv. Revenue By Shri Ramnath P Murkunde – Dr Date Of Hearing 15/09/2022 Date Of Pronouncement 08/12/2022 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of The Ld.Commissioner Of Income Tax(Appeal)-1, Pune Dated 27.02.2017 Emanating From The Order Of The Assessing Officer Under Section 143(3) Dated 28.03.2015. The Grounds Of Appeal By The Assessee Are As Under : “1. The Learned Cit(A) Erred In Making Addition Of Rs.5,32,734 Towards Sales Tax Paid & Written Off In Profit & Lost Account. 2. The Learned Ao & Cit(A) Erred In Making Addition Of 17,80,000 By Capitalizing Interest Expenditure Over The Value Of Agriculture Lands Without Appreciating The Facts & Submission Of The Appellant That Borrowed Loans Were Used For Business Purposes & Hence, Interest Was A Deductible Revenue Expenditure.

Section 133ASection 143(3)

that the assessee filed Return of Income for A.Y. 2012-13 on 15.09.2012 declaring total income of Rs.71,24,570/-. However, assessee filed revised return on 30.03.2013 revising the total income To Rs.47,27,330/-. The case was selected for scrutiny. The Assessing Officer(AO) passed assessment order ... original Return of Income, the assessee had not claimed Rs.17,80,000/- as interest expenditure and the said amount was capitalized, however, in the revised return, assessee claimed it as business expenditure, and had submitted before the AO that it was wrongly capitalized. The AO stated that assessee had purchased

Subramanian Sreeram, Bangalore vs. CIT(Appeals)-NFAC, National Faceless Appeal Centre

The appeal is allowed in favour of the assessee

ITA 1027/BANG/2022[2021-22]Status: DisposedITAT Bangalore08 Dec 2022AY 2021-22

Bench: Shri N.V. Vasudevan & Ms. Padmavathy Sassessment Year : 2021-22

For Appellant: Shri Navneet N. Kini, CAFor Respondent: Shri Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 143(1)Section 90

claimed FTC of Rs. 4,73,779/- u/s. 90 of the Act read with Article 24 of India Australia tax treaty ("DTAA") in a revised return of income filed on 31-8-2018. The Assessee had not filed the Form 67 before filing the return of income. On realising ... same, the Assessee filed Form 67 in support of claim of foreign tax credit on 18-4-2020. The revised return of income was processed by Centralized Processing Centre (CPC) electronically and intimation u/s 143(1) of the Act on 28-5-2020 was passed disallowing the claim

Rupesh Vyas, Indore vs. The ACIT3(1), Indore

In the result, this appeal of assessee is dismissed

ITA 909/IND/2018[2014-15]Status: DisposedITAT Indore07 Dec 2022AY 2014-15

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani

Section 10(38)Section 143(3)Section 68Section 69C

LTCG amounting to several crores. vi) Many such individuals have voluntarily without any enquiry by any authority have voluntarily withdrawn their claim and filed revised return. vii) Statements of brokers, operators, director of paper companies that has bought these shares, directors of Penny stock companies all confess to such

The DCIT, Circle-2(1)(1), Ahmedabad vs. M/S. Ecs Environment Pvt. Ltd, Ahmedabad

In the result, the appeal of the Revenue is hereby dismissed

ITA 1690/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad07 Dec 2022AY 2015-16

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकर अपील सं./Ita No. 1690/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2015-2016 D.C.I.T., M/S. Ecs Environment Pvt. Ltd., Circle-2(1)(1), Vs. 11-12, Ecs House, Ahmedabad. Garden View, Opp. Auda Garden, Opp. D.G. Highway, Ahmedabad.

For Appellant: Shri Sunil Maloo, A.RFor Respondent: Shri V.K. Mangla, JCIT, D.R

Section 143(3)Section 271Section 271(1)Section 271(1)(c)

Assessing Authority could not have adopted these imaginary figures of alleged evaded income tax on the "reduction of loss" as claimed in the Revised Return filed by the Assessee and as the basis for "assumed income tax liability" thereon, 100% penalty thereon could not have been imposed. 9.4 In view

Alidhara Texspin Engineers, Dadra Ut of D & Nh vs. The ACIT., Vapi Circle, Vapi

In the result, assessee`s appeal is partly allowed in above terms

ITA 446/SRT/2018[2014-15]Status: DisposedITAT Surat06 Dec 2022AY 2014-15

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.446/Srt/2018 (िनधा"रणवष" / Assessment Year: (2014-15) (Virtual Court Hearing) Alidhara Texspin Engineers Assistant Commissioner Of Income Plot No.2, Block No.122,Vaghdhara Tax, Vapi Circle, Vapi Vs. Road, Dadra "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaifa 2434 N (Appellant ) (Respondent)

For Appellant: Shri Mehul Shah, C.AFor Respondent: Shri Vinod Kumar– Sr.DR

Section 143(1)Section 143(3)Section 14A

No.446/SRT/2018 A.Y. 2014-15 Alidhara Texspin Engineers return of income declaring total income of Rs.19,33,38,980/- on 25.11.2014 and subsequently filed its revised return declaring a revised income of Rs.18,78,37,840/-. Both these return were processed under section 143(1) of the Act by CPC Bangalore

Rupesh Vyas, Indore vs. The ACIT3(1), Indore

In the result, this appeal of assessee is dismissed

ITA 50/IND/2020[150-16]Status: DisposedITAT Indore06 Dec 2022

Bench: Shri T.R. Senthil Kumar & Shri B.M. Biyani

Section 10(38)Section 143(3)Section 68Section 69C

Virgo Aluminum Ltd., Sirmour vs. Pr. C.I.T., Circle, Patiala

In the result, appeal of the assessee stands allowed

ITA 438/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh06 Dec 2022AY 2017-18

Bench: Shri Sanjay Garg & Shri Vikram Singh Yadavआयकर अपील सं./ Ita No. 438/Chd/2022 "नधा"रण वष" / Assessment Year : 2017-18

For Appellant: Shri Manoj Kumar, CAFor Respondent: Sh. Rohit Sharma, CIT DR

Section 143(3)Section 263Section 263oSection 80Section 80I

80IC(2)(a)(ii) of the Act amounting to Rs.3,24,45,802/- for the first time for the year under consideration in the Revised return of income, which was filed on 07.09.2018. The requisite Audit Report in Form 10CCB was, however, filed on 11.09.2018. Thus, the audit report ... observation of your goodself vide Para-4 of the notice, it is submitted that for the relevant assessment year, due date of filing the revised return of income was 31.03.2019. So, the revised return filed on 07.09.2018 was much earlier than the due date. Within 4 days of filing

Principal Commissioner of Income Tax-04 vs. M/S Microsoft India (R and D) Pvt Ltd

ITA - 509 / 2022HC Delhi06 Dec 2022

Bench: The Next Date Of Hearing.

Section 56

Order is downloaded from the DHC Server on 27/03/2026 at 14:14:52 2.1 The record seems to reveal, that the respondent/assessee, in the revised return, had claimed the rent received from the subject building as “income from other sources”. 3. Unfortunately, the appellant/revenue has not placed on record

Purushothama Reddy Vanki Reddy, Tirupathi vs. ADIT, (Int. Taxn)-1, Hyderabad

In the result, appeal of the assessee is allowed and the stay application is dismissed

ITA 526/HYD/2022[2018-19]Status: DisposedITAT Hyderabad05 Dec 2022AY 2018-19

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charyआ.अपी.सं / Ita No. 526/Hyd/2022 (निर्धारण वर्ा / Assessment Year: 2018-19) Purushothama Reddy Vs. Adit (Intn Taxation)-1, Vankireddy Hyderabad Tirupathi [Pan No. Aetpv4382D] अपीलधर्थी / Appellant प्रत्‍यर्थी / Respondent S.A. No. 19/Hyd/2022 (Arising Out Of Ita No.526/Hyd/2022) (निर्धारण‍वर्ा / Assessment Year: 2018-19) Purushothama Reddy Adit (Intn Taxation)-1, Vankireddy Vs Hyderabad Tirupathi [Pan No. Aetpv4382D] आवेदक / Applicant प्रत्‍यर्थी / Respondent निर्धाररती‍द्वधरध / Assessee By: Shri H. Srinivasulu, Ar रधजस्‍व‍द्वधरध / Revenue By: Ms. Swapna, Dr सुिवधई‍की‍तधरीख/Date Of Hearing: 29/11/2022 घोर्णध की‍तधरीख/Pronouncement On: 05/12/2022 आदेश / Order Per K. Narasimha Chary, Jm: Aggrieved By The Order Dated 11/08/2022 Passed By The Learned Commissioner Of Income Tax (Appeals)-10, Hyderabad (“Ld. Cit(A)”), In The S.A.No. 19/Hyd/2022 Case Of Purushothama Reddy Vankireddy (“The Assessee”) For The Assessment Year 2018-19, Assessee Preferred This Appeal.

For Appellant: Shri H. Srinivasulu, ARFor Respondent: Ms. Swapna, DR

Section 139Section 139(1)Section 139(5)Section 295(1)

income on which the assessee paid the tax as per rules and claims credit thereof. Assessee, however, uploaded the Form 67 along with the revised return of income. Authorities below, therefore, denied to give credit of the foreign tax paid by the assessee holding that the assessee violated the mandatory

Basant Vihar Co-Operative Housing Society Limited, Mumbai vs. ITO 27(1)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 2539/MUM/2022[2014-15]Status: DisposedITAT Mumbai05 Dec 2022AY 2014-15

Bench: Shri Aby T. Varkey, Jm आयकर अपील सं/ I.T.A. No.2539/Mum/2022 (निर्धारण वर्ा / Assessment Years: 2014-15) Basant Vihar Cooperative बिधम/ Ito-27(1)(2) 4Th Floor, Tower No. 6, Housing Society Ltd Vs. Vasant Vihar Complex A Vashi Railway Station Building, Ground Floor, Dr. Commercial Complex, C. G. Road Chembur, Vashi, Navi Mumbai- Mumbai-400074. 400703. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaajb0835E (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Venugopal C. Nair Revenue By: Smt. Nayana K. Kumar सुनवाई की तारीख / Date Of Hearing: 28/11/2022 घोषणा की तारीख /Date Of Pronouncement: 05/12/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Co-Operative Society Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi Dated 29.07.2022 For The Assessment Year 2014-15. 2. The Grounds Of Appeal Of The Assessee Reads As Under: -

For Appellant: Shri Venugopal C. NairFor Respondent: Smt. Nayana K. Kumar

Section 143(3)Section 80P(2)(d)

society had filed return of income for AY. 2014-15 on 24.12.2015 declaring a total income of Rs. Nil. Subsequently, the assessee has filed revised return of income on 28.01.2016 declaring total income of Rs.4,65,111/-. During the year, the society has earned interest income of Rs.12

Deputy Commissioner of Income Tax, Circle-1(1), Hubballi vs. M/S. Karnataka Vikas Grameen Bank Limited, Dharwad

In the result, the appeal of assessee is partly allowed and the appeal of the revenue is dismissed

ITA 720/BANG/2020[2016-17]Status: DisposedITAT Bangalore05 Dec 2022AY 2016-17

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2016-17

For Appellant: Shri S Ananthan, C.AFor Respondent: Ms. Susan D George, CIT (DR)

Section 143Section 234BSection 250Section 36

right in allowing the fresh claim of the assessee during the course of appellate proceeding in the absence of revised return of income ignoring the judgment in the case of Goetze (India) Ltd Vs CIT 284 itr 323 (SC)." ITA Nos.611 & 720/Bang/2020 Page 25 of 27 23. The ld.DR submitted ... that the CIT(A) has accepted the claim of the assessee without revising return of income filed by him ignoring judgment in the case of Goetze (India) Ltd., Vs. CIT reported in 284 ITR 323 (SC), therefore the CIT(A) is not justified in giving relief to the assessee, hence

Dion Global Solutions Ltd., New Delhi vs. DCIT, Circle-7(2), New Delhi

ITA 5218/DEL/2019[2009-10]Status: DisposedITAT Delhi05 Dec 2022AY 2009-10

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra[Assessment Year : 2009-10] Dion Global Solution Ltd., Vs Dcit, 409, Chaudhry Complex, Circle-7(2), New Delhi. 9 Vs Block, Madhuban Road, Shakarpur, New Delhi-110092 Pan-Aaacf1917E Appellant Respondent Appellant By None Respondent By Shri Akhilesh Gupta, Sr Dr Date Of Hearing 06.12.2022 Date Of Pronouncement 06.12.2022

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 14ASection 9(5)

income through electronic mode, declaring loss of Rs.19,32,583/- on 2 | P a g e 30.09.2009. Thereafter, the assessee company furnished a revised return loss of Rs.1,31,66,556/- was filed on 31.03.2011. The return of income was processed u/s 143(1) of the Income

Jaigopal Garodia Vivekananda Vidyalaya Trust, Chennai vs. DDIT (Exemptions) III, Chennai

In the result, appeals filed by the assessee for the AYs 2010-11 to

ITA 1353/CHNY/2019[2013-14]Status: DisposedITAT Chennai02 Dec 2022AY 2013-14

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.1350-1353/Chny/2019 िनधा"रण वष" /Assessment Years: 2010-11 To 2013-14 M/S.Jaigopal Garodia Vivekananda- V. The Dy. Director Of Income- Vidyalaya Trust, Tax (Exemptions)-Iii, U-6, Seventh Street, Anna Nagar, Chennai. Chennai-600 040. [Pan: Aaatj 0208 R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.S.Sridhar, Adv. &For Respondent: Mr.P.Sajit Kumar, JCIT

Section 1Section 11(2)Section 11(6)

open the assessment beyond six years and further, any fresh claim towards expenditure or allowance, can be made only by filing a revised return. Since, the assessee has made a claim without any revised return, the AO has rejected the claim of the assessee. We have gone through the reasons ... assessee, should allow depreciation allowable as per law. Further, arguments of the AO that any fresh claim can be made only by filing a revised return, we find that although, the law restricts the AO to admit any fresh claim without any revised return, but there is no prohibition

Jaigopal Garodia Vivekananda Vidyalaya Trust, Chennai vs. DDIT (Exemptions) III, Chennai

In the result, appeals filed by the assessee for the AYs 2010-11 to

ITA 1352/CHNY/2019[2012-13]Status: DisposedITAT Chennai02 Dec 2022AY 2012-13

For Appellant: Mr.S.Sridhar, Adv. &For Respondent: Mr.P.Sajit Kumar, JCIT

Section 1Section 11(2)Section 11(6)

Jaigopal Garodia Vivekananda Vidyalaya Trust, Chennai vs. DDIT (Exemptions) III, Chennai

In the result, appeals filed by the assessee for the AYs 2010-11 to

ITA 1351/CHNY/2019[2011-12]Status: DisposedITAT Chennai02 Dec 2022AY 2011-12

For Appellant: Mr.S.Sridhar, Adv. &For Respondent: Mr.P.Sajit Kumar, JCIT

Section 1Section 11(2)Section 11(6)

Jaigopal Garodia Vivekananda Vidyalaya Trust, Chennai vs. DDIT (Exemptions) III, Chennai

In the result, appeals filed by the assessee for the AYs 2010-11 to

ITA 1350/CHNY/2019[2010-11]Status: DisposedITAT Chennai02 Dec 2022AY 2010-11

For Appellant: Mr.S.Sridhar, Adv. &For Respondent: Mr.P.Sajit Kumar, JCIT

Section 1Section 11(2)Section 11(6)

Michael Page International Pte Limited, Mumbai vs. Dy CIT (International Tax) -3(2)(2) Mumbai, Mumbai

In the result, appeal by the assessee is partly allowed

ITA 751/MUM/2022[2018-19]Status: DisposedITAT Mumbai02 Dec 2022AY 2018-19

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं. 751/मुं/ 2022 ("न.व. 2018-19) Michael Page International Pte Limited, C/O.Michael Page International Recruitment Pvt. Ltd., 5Th Floor, 2North Avenue, Maker Maxity, Bandra Kurla Compelx, Mumbai -400 051 Pan:Aahcm-6965-A ...... अपीलाथ" /Appellant बनाम Vs. The Deputy Commissioner Of Income-Tax (International Tax), Circle – 3(2)(2) Mumbai, Room No.X. 16Th Floor, Air India Bldg., Nariman Point,Mumbai – 400 021 ..... ""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By : Shri Pratik Shah & Ms.Riddhi Maru ""तवाद" "वारा/Respondent By : Shri Soumendu Kumar Dash सुनवाई क" "त"थ/ Date Of Hearing : 06/09/2022 घोषणा क" "त"थ/ Date Of Pronouncement : 02/12/2022 आदेश/ Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Directed Against The Assessment Order Dated 23/02/2022 Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 [In Short ‘The Act’]For The Assessment Year 2018-19. 2 2. The Assessee In Appeal Has Assailed The Assessment Order By Raising Following Grounds:

For Appellant: Shri Pratik Shah & Ms.Riddhi MaruFor Respondent: Shri Soumendu Kumar Dash

Section 143(3)Section 270ASection 9(1)(vii)

assessee in original return of income for assessment year 2018-19 offered the aforesaid fee for taxation. Thereafter, the assessee filed revised return of income for assessment year 2018-19 and claimed referral fee received for business support services as not taxable and sought refund of Rs.42

Rohan Hattangadi, Mumbai vs. Commissioner of Income Tax (Appeal), Mumbai

In the result, the appeal of the assessee is allowed

ITA 1896/MUM/2022[2020-21]Status: DisposedITAT Mumbai02 Dec 2022AY 2020-21

Bench: Shri M. Balaganesh, Am & Ms. Kavitha Rajagopal, Jm Rohan Hattangadi Cit(A), 32,33/A, Peace Haven Society, Faceless Appeal Centre, Vs. Bandra, Mumbai-400 050 Delhi

For Appellant: Shri Niraj ShethFor Respondent: Shri Manoj Kumar Singh

Section 139(5)Section 244ASection 250Section 90

learned NFAC has erred in not granting of foreign tax relief amounting to Rs.26,718 as claimed by the appellant in the revised Return of Income. 2.2 The learned NFAC ought to have appreciated that income of Rs.4,12,835 is doubly and the appellant being resident of India, taxes ... India-Sri Lanka Tax Treaty. 2.3 The learned NFAC has erred in not considering the Form 67 and other document, submitted before filing revised return, for claiming foreign tax relief by the appellant. 2.4 The learned NFAC erred in upholding the action of learned AO in not allowing foreign