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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

Microland Foundation, Bangalore vs. The Income Tax Officer (Exemptions), Ward-2, Bangalore

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

ITA 410/BANG/2022[2017-18]Status: DisposedITAT Bangalore01 Sept 2022AY 2017-18

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: --- None ---For Respondent: Sri.K.R.Narayana, Addl.CIT-DR
Section 11(2)Section 13(9)Section 139(1)Section 143(1)Section 143(3)Section 3

follows: The assesee is a public charitable trust. For the assessment year 2017-2018, the return of income was filed on 31.10.2017. Subsequently a revised return was filed on 29.11.2017 declaring total income of Rs.46,31,670. During the relevant assessment year, the assessee had accumulated income amounting to Rs.93

Schneider Electric It Business India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Ltu, Circle-2, Bangalore

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

ITA 185/BANG/2022[2017-18]Status: DisposedITAT Bangalore01 Sept 2022AY 2017-18

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.185/Bang/2022 Assessment Year: 2017-18

For Appellant: Shri Rohit Tiwari, A.RFor Respondent: Shri Manjunath Karkihalli, D.R
Section 143(3)Section 144BSection 144C(13)Section 92D

proceedings. 14.1 We have heard the rival submissions and perused the materials available on record. The assessee has made claim on this count in revised return. The Ld. DRP has directed the AO to verify the validity of revised return so claimed to have been filed by the assessee ... consider the same if the revised return is valid return as per the provisions of the Act for computing total income of the assessee. In our opinion, appellate authority could entertain the claim of assessee, even though no revised return is filed. Hence, we direct the Ld. DRP to examine

Yogesh Das, Jaipur vs. ITO, Jaipur

ITA 983/JPR/2016[2013-14]Status: DisposedITAT Jaipur31 Aug 2022AY 2013-14
For Appellant: Shri S.L. Poddar, AdvocateFor Respondent: Shri Avdhesh Kumar, CIT-DR
Section 139Section 143Section 147Section 148Section 50C

pursuance of a notice issued under sub-section (1) of section 142discovers any omission or any wrong statement therein, he may furnish a revised return at any time before the expiry of one year from the end ofthe relevant assessment year or before the completion of the assessment, whichever

The ACIT, Circle-2(1)(2), Ahmedabad vs. Kansara Popatlal Tribhovandas Metal Pvt. Ltd., Ahmedabad

In the result, the appeal of the Revenue is dismissed while the Cross

ITA 412/AHD/2018[2012-13]Status: DisposedITAT Ahmedabad31 Aug 2022AY 2012-13

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyal

For Appellant: Shri M.J. Shah, AR &For Respondent: Shri Shramdeep Sinha, Sr DR
Section 143(2)

knowledge at the time of filling return. The reply of the assessee company is not acceptable as any mistake can be rectified by filing revised return of income in due course. As per letter of regulatory authority it is clear that the credit of power generation was withdrawn from

Vrindavan Tubes Ltd., Meerut vs. ACIT, Circle-26(2), New Delhi

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

ITA 5425/DEL/2019[2015-16]Status: DisposedITAT Delhi31 Aug 2022AY 2015-16

Bench: Shri C.M. Garg & Shri Pradip Kumar Kediaassessment Year: 2015-16 Vrindavan Tubes Ltd., Vs. Acit, C/O Kashyap & Co., Circle-26(2), 114, Citi Centre, New Delhi. B.B. Road, Meerut. Pan: Aaccv2294C (Appellant) (Respondent) Assessee By : Shri P.S. Kashyap, Fca Revenue By : Shri Anil Kumar Sharma, Sr. Dr Date Of Hearing : 24.08.2022 Date Of Pronouncement : 31.08.2022 Order Per C.M. Garg, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 09.04.2019 Of The Cit(A)-9, New Delhi, Relating To Assessment Year 2015-16. 2. The Grounds Of Appeal Raised By The Assessee Read As Under:- “1. That On Facts & In Law Notice U/S 274 R.W.S 271(1)( C) Of The Act Is Not Maintainable. Ld. Ao Has Given Notice Without Specifying Whether There Is Concealment Of Income Or Assessee Has Furnished Inaccurate Particulars Of Income. The Notice U/S 274 R.W.S 271(1)(C) Is Void Ab Initio. 2. That On Facts & In Law Imposing The Penalty Under Section 271(1)(C ) For Rs. 77,47,664/- Is Totally Wrong, Unjustified & Illegal. The Appellant Had Never Furnished Any Inaccurate Particulars Or Concealed Income At Any Stage Of Assessment Proceedings As Well As In Penalty Proceedings. The Penalty Imposed U/S 271(1)(C) Ought To Be Deleted In Full.”

For Appellant: Shri P.S. Kashyap, FCAFor Respondent: Shri Anil Kumar Sharma, Sr. DR
Section 143(2)Section 143(3)Section 271(1)Section 271(1)(c)Section 274Section 43B

scrutiny. In penalty order u/s 271(1)(c ) the AO stated that in its reply the assessee has submitted that voluntarily filing the revised return of income by the assessee on its own well within the time allowed under the IT Act, 1961 does not make the assessee liable ... that penalty is not leviable on this account. 5. Replying to the above, the ld. Sr. DR strongly contended that the assessee filed its revised return of income declaring a loss of Rs.52,46,647/- after making disallowance u/s 43B on account of interest on bank loan amounting to Rs.1

Sai Service Agency(B0Mbay) P Ltd, Pune vs. Deputy Commissioner of Income-Tax, Circle -8, Pune

Appeal is partly allowed in above terms

ITA 490/PUN/2021[2017-18]Status: DisposedITAT Pune30 Aug 2022AY 2017-18

Bench: Shri S.S.Godara & Shri G.D.Padmashaliआयकर अपीलसं. / Ita No.490/Pun/2021 िनधा"रणवष" / Assessment Year : 2017-18 Sai Service Agency (Bombay) The Dcit, Circle-8, Pune. Pvt. Ltd., Vs Mumbai Pune Road, . Phugewadi, Pune – 411012. Pan: Aaccs 5991 F Appellant/ Assessee Respondent /Revenue Assessee By Shri Deepa Khare – Adv. Revenue By Shri Arvind Desai – Dr Date Of Hearing 17/08/2022 Date Of Pronouncement 30/08/2022 आदेश/ Order Per S.S.Godara, Jm: This Assessee’S Appeal For Assessment Year 2010-11 Is Directed Against The Commissioner Of Income Tax(Appeals), Pune- 8’S Order Dated 05.08.2019 Passed In Case No.Pn/Cit(A)-8/Dcitc Cir-1(2)/202/18-19/188, In Proceedings U/S.143(3) R.W.S. 147 Of The Income Tax Act, 1961 [In Short “The Act”].

Section 139Section 139(1)Section 143(3)Section 14ASection 36(1)(va)Section 43BSection 80A(5)Section 80CSection 80G

thereof. Rejected accordingly. 7. Next comes section 80G disallowance of Rs.11 lakhs made in both the lower proceedings for want of the assessee’s revised return filed before the Assessing Officer. The Revenue quotes section 80A(5) read with section 80C of the Act as well as hon’ble apex ... foregoing decision also makes it clear in para 4 thereof that appellate authorities’ jurisdiction to entertain such a new claim even in absence a revised return has nowhere been impinged upon in any manner whatsoever. Faced with this situation, we restore the ITA No.490/PUN/2021 for A.Y. 2017-18 Sai Service

Assistant Commissioner of Income-Tax, Circle - 11, Pune vs. Hsbc Software Development (India) Private Limited, Pune

In the result, CO of assessee is allowed and the appeals of Revenue are dismissed

ITA 2348/PUN/2017[2011-12]Status: DisposedITAT Pune30 Aug 2022AY 2011-12

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Respondent: Shri Percy Jal Pardiwalla
Section 10A(7)Section 10BSection 10B(7)Section 143(3)Section 80I

been held that an assessee can amend a return filed by him for making a claim for deduction only by filing a revised return. 5. The Ld Commissioner of Income Tax (Appeals) erred on the facts and in the circumstances of the case and in law in allowing alternate claim

Assistant Commissioner of Income-Tax, Circle -11, Pune vs. Capgemini Technology Services India Limited, (Formerly Igate Global Solutions Ltd.), Pune

In the result, both the appeals are partly allowed

ITA 1935/PUN/2017[2013-14]Status: DisposedITAT Pune30 Aug 2022AY 2013-14

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

Section 10ASection 115JSection 391Section 72ASection 74

Pune unit without appreciating the fact that such deduction was not claimed in the original return of income but was claimed in the revised return of income and further Form No. 56F was uploaded at the time of filing of the revised return. 55. The facts of this ground ... this unit in the original return. The assessee claimed deduction of Rs.5,23,54,148/- in respect of such unit only in the revised return and further Form No.56F was also uploaded at the time of filing of the revised return. The ld. CIT(A) overturned the assessment order

Capgemini Technology Services India Ltd, Pune vs. Deputy Commissioner of Income-Tax, Circle - 11, Pune

In the result, both the appeals are partly allowed

ITA 1857/PUN/2017[2013-14]Status: DisposedITAT Pune30 Aug 2022AY 2013-14

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

Section 10ASection 115JSection 391Section 72ASection 74

Pune unit without appreciating the fact that such deduction was not claimed in the original return of income but was claimed in the revised return of income and further Form No. 56F was uploaded at the time of filing of the revised return. 55. The facts of this ground ... this unit in the original return. The assessee claimed deduction of Rs.5,23,54,148/- in respect of such unit only in the revised return and further Form No.56F was also uploaded at the time of filing of the revised return. The ld. CIT(A) overturned the assessment order

Assistant Commissioner of Income-Tax, Circle - 11, Pune vs. Hsbc Software Development (India) Pvt.Ltd, Pune

In the result, CO of assessee is allowed and the appeals of Revenue are dismissed

ITA 1464/PUN/2017[2010-11]Status: DisposedITAT Pune30 Aug 2022AY 2010-11

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Respondent: Shri Percy Jal Pardiwalla
Section 10A(7)Section 10BSection 10B(7)Section 143(3)Section 80I

been held that an assessee can amend a return filed by him for making a claim for deduction only by filing a revised return. 5. The Ld Commissioner of Income Tax (Appeals) erred on the facts and in the circumstances of the case and in law in allowing alternate claim

Assistant Commissioner of Income Tax Central Circle3-(1), Hyderabad vs. Ramky Energy and Environment Ltd, Hyderabad

In the result, both the appeals filed by the Revenue are partly allowed

ITA 775/HYD/2020[2014-15]Status: DisposedITAT Hyderabad30 Aug 2022AY 2014-15

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Shri Vishal Kalra, CAFor Respondent: Shri K P R R Murty, (D.R)
Section 143(2)Section 21Section 25Section 36(1)(va)Section 80I

they are to be literally construed, more particularly in a case of exemption sought by an assessee. 9. In such a situation, filing a revised return under section 139(5) of the IT Act claiming carrying forward of losses subsequently would not help the assessee. In the present case ... assessee filed its original return under section 139(1) and not under section 139(3). Therefore, the Revenue is right in submitting that the revised return filed by the assessee under section 139(5) can only substitute its original return under Section 139(1) and cannot transform it into

Assistant Commissioner of Income Tax Central Circle3(1), Hyderabad vs. Ramky Energy and Environment Limited, Hyderabad

In the result, both the appeals filed by the Revenue are partly allowed

ITA 774/HYD/2020[2013-14]Status: DisposedITAT Hyderabad30 Aug 2022AY 2013-14

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Shri Vishal Kalra, CAFor Respondent: Shri K P R R Murty, (D.R)
Section 143(2)Section 21Section 25Section 36(1)(va)Section 80I

they are to be literally construed, more particularly in a case of exemption sought by an assessee. 9. In such a situation, filing a revised return under section 139(5) of the IT Act claiming carrying forward of losses subsequently would not help the assessee. In the present case ... assessee filed its original return under section 139(1) and not under section 139(3). Therefore, the Revenue is right in submitting that the revised return filed by the assessee under section 139(5) can only substitute its original return under Section 139(1) and cannot transform it into

Shri Kandasamy Velayudam, Chennai vs. ITO, Corporate Ward 6(1), Chenai

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

ITA 572/CHNY/2022[2016-2017]Status: DisposedITAT Chennai30 Aug 2022AY 2016-2017

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No. 572/Chny/2022 िनधा"रण वष"/Assessment Year:2016-17 Shri Kandasamy Velayudam, Vs. The Income Tax Officer, Flat No. 25/29, Sakthi Srinivasan Salai, Corporate Ward 6(1), Kumaran Kudil, Thoraipakkam, Chennai. Chennai 600 097. [Pan:Aempv6412K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Mrs. Sree Lakshmi Valli, Advocate Shri I. Dinesh, Advocate ""थ" की ओर से/Respondent By : Shri Ar.V. Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 25.08.2022 घोषणा की तारीख /Date Of Pronouncement : 30.08.2022 आदेश /O R D E R Per V. Durga Rao:

For Appellant: Mrs. Sree Lakshmi Valli, AdvocateFor Respondent: Shri AR.V. Sreenivasan, Addl. CIT
Section 139(5)Section 143(3)Section 154

considered by the Assessing Officer. After considering the submissions of the assessee, the Assessing Officer has concluded that the assessee has not filed any revised return of income under section 139(5) of the Act and therefore, the plea of the assessee was not considered and moreover, there ... assessee has submitted that the ld. CIT(A) has failed to adjudicate on a deduction claimed by the assessee without filing the revised return of income and the decision of the Hon’ble Supreme Court in Goetze (India) Ltd.’s case has not prohibited to make such claim before

Shree Global Tradefin Ltd, Mumbai vs. CIT, Central Circle 5(1), Mumbai

In the result, appeal is allowed

ITA 511/MUM/2022[2015-16]Status: DisposedITAT Mumbai30 Aug 2022AY 2015-16
For Appellant: Sh. Vijay MehtaFor Respondent: Ms. Vrunda Matkarni
Section 119(2)(b)Section 143(3)Section 14A

lodged by the Appellant before the Assessing Officer vide letter dated 10.10.2017. According to the CIT(A), the time limit for filing the revised return had expired by the time Appellant lodged the aforesaid claim. Further, the Appellant had also not sought extension of time to file the claim ... Court in the case of 'Goetze (India) Limited v. CIT' (2006) 157 Taxman 1, relating to the restriction of making the claim through a revised return was limited to the powers of the Assessing Authority and the said judgment does not impinge on the power or negate the powers

M/S. B B Jewellers and Finance Private Limited, Bengaluru vs. The Assistant Commissioner of Income Tax, Circle-1(1)(2), Bengaluru

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

ITA 557/BANG/2022[2016-17]Status: DisposedITAT Bangalore30 Aug 2022AY 2016-17

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Sri.Madhusudhan, AdvocateFor Respondent: Smt.Priyadarshini Baseganni, Addl.CIT-DR
Section 143(3)Section 154Section 234Section 234BSection 250Section 68

silver articles. For the assessment year 2016-2017, the return of income was filed on 16.10.2016 declaring a loss of Rs.1,32,893. Revised return was filed on 03.11.2017 without any change in income / loss declared earlier, but change in cash balance. The assessment was selected for scrutiny and order ... I.T.Act to the total income (since there was an increase of cash in hand by Rs.30,00,000 between original return and the revised return). The assessee sought for a personal hearing, which was duly granted. The assessee raised objections to the rectification notice issued by the A.O. However

Microsoft Regional Sales Pte Ltd, New Delhi vs. ACIT Circle-2(2)(1) - International Taxation, New Delhi

Appeal are allowed and the remaining grounds being consequential in nature follow the event

ITA 312/DEL/2021[2017-18]Status: DisposedITAT Delhi30 Aug 2022AY 2017-18

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmamicrosoft Regional Sales Pte. Ltd. Vs. Assistant Commissioner Of Income- C/O. Mr. Nirman Malpani Ernst & Tax, Young Llp Circle-2(2)(1), 3Rd & 6Th Floor, Worldmark 1, Intl. Taxation, Delhi Igi Airport Hospitality District, Aerocity, New Delhi-110037 Pan : Aadcm1638A (Appellant) (Respondent)

Section 144

allowed. 2.1 Assessee had filed a return of income declaring Nil income on 31.10.2017 claiming TDS of Rs. 9,28,94,483/- and a revised return declaring the same Nil income claiming TDS of Rs. 9,74,72,239/- was filed on 29.03.2019. 2.2 The case was selected for scrutiny

ACIT Circlie-19, New Delhi vs. Pawan Kansal, New Delhi

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

ITA 5110/DEL/2019[2010-11]Status: DisposedITAT Delhi30 Aug 2022AY 2010-11

Bench: Shri C.M. Garg & Shri Pradip Kumar Kediaassessment Year: 2010-11 Acit, Vs. Pawan Kansal, Circle-19, A-7, Antriksh Apartment, New Delhi. Plot No.D-3, Sector-14, New Delhi. Pan: Ahepk0574C

For Appellant: Shri Ved Jain, CA &For Respondent: Ms Sapna Bhatia, CIT, DR
Section 153A

Kabul Chawla (supra) is concerned, undisputedly, the assessee filed return of income for AY 2010-11 on 30.09.2010 and, thereafter, e-filed the revised returned on 10.03.2011. The return was processed u/s 143(1) on 25.06.2011 and, thereafter, the case was selected for scrutiny under CASS by issuing notice

Mahesh Kumar Agrawal, Jaipur vs. ACIT Circle 7 Jaipur, Jaipur

In the result, the appeal of the assessee is allowed

ITA 194/JPR/2021[2012-13]Status: DisposedITAT Jaipur29 Aug 2022AY 2012-13
For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri A.S. Nehara (Addl.CIT) a
Section 139(1)Section 147Section 148Section 271(1)(c)Section 274

filing its return on 28.07.2012 to the date of notice u/s 148 i.e. 13.10.2014, there was sufficient period with the assessee to filed a revised return to meet out the said mistake of wrongly filed income. But the assessee did not file any revised return. In response to the notice ... INCOME-TAX v. MAHABIR PRASAD BAJAJ, [2008]298 ITR 109 (JHARKHAND) Penalty—Concealment of Income—Incriminating documents found during search—Contention by assessee that —Revised return accepted —Revised return filed not voluntarily but owing to search and seizure— Levy of penalty proper Income

Saj Testplant Private Limited, Pune vs. Deputy Commissioner of Income-Tax, Circle - 6, Pune

In the result, the appeal is allowed for statistical purposes

ITA 388/PUN/2020[2007-08]Status: DisposedITAT Pune29 Aug 2022AY 2007-08

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviनिर्धारण वषा / Assessment Year : 2007-08 Saj Test Plant Private Limited Vs. Dcit, 72/76, Mundhwa, Circle 6, Pune Pune Cantonment, Pune – 411036 Pan : Aabcs4227K Appellant Respondent

Section 139(5)Section 143(1)

relation to the assessment year 2007-08. 2. The only issue raised in this appeal is against not accepting the second revised return filed by the assessee and consequently disallowing deduction of Rs.2,91,062 claimed by the assessee. 3. Succinctly, the facts of the case are that the assessee ... analyzers, which are used for testing automobiles. A return was filed declaring total income under normal provisions at Rs.2,71,94,190. The first revised return was filed on 12.03.2008 showing total income of Rs.2,66,60,760, in which commission payable of Rs.5,33,430 was deducted. Thereafter

DCIT Circle-13, Pune vs. Shri Ajay Bhalchandra Pathak, Pune

ITA 1890/PUN/2019[2008-09]Status: DisposedITAT Pune29 Aug 2022AY 2008-09

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपीलसं. / Ita No.1890/Pun/2019 िनधा"रणवष" / Assessment Year : 2008-09 The Dcit, Circle-13, Shri Ajay Bhalchandra Pathak, Pune. Vs. 35, Lic Colony, Parvati, Pune Satara Road, Parvati, Pune – 411037. Pan: Aarpp 6124 F Appellant/ Assessee Respondent /Revenue Assessee By Shri Nikhil Pathak – Ar Revenue By Shri Arvind Desai – Dr Date Of Hearing 08/08/2022 Date Of Pronouncement 29/08/2022 आदेश/ Order Per S.S.Godara, Jm: This Revenue’S Appeal For Assessment Year 2008-09 Is Directed Against The Commissioner Of Income Tax(Appeals)-2, Pune’S Order Dated 30.09.2019 Passed In Appeal No.Pn/Cit(A)- 2/Acit Hq Ii/Pn/209/2015-16, In Proceedings U/S.143(3) Of The Income Tax Act, 1961 [In Short “The Act”].

Section 143(3)Section 2(47)Section 45

evident that the appellant filed ITR-2 for the year under consideration on 26/06/2008 declaring total income at Rs. 44,47,432/- and a revised return on 30/07/2008 declaring total income at Rs. 32,62,670/-. During the appeal proceedings, the AR of the Appellant argued that the alleged foreign