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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

Mr K. P. Manjunatha Reddy, Bangalore vs. The Income Tax Officer, Ward 4(3)(2), Bangalore

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

ITA 977/BANG/2019[2014-15]Status: DisposedITAT Bangalore25 Mar 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2014-15

For Appellant: Shri Thirumala Naidu, A.RFor Respondent: Smt. Priyadarshini Mishra, D.R
Section 10(1)Section 143(3)Section 2(14)Section 271(1)(c)

Rs.14,17,87,795/- as Capital Gains from the above transaction in its original return of Income furnished to the Department. Subsequently, in its revised return of Income dated 15.6.2009, the assessee had admitted income of Rs.22,90,570/-, on the ground that the capital gains which arose

ACIT, New Delhi vs. M/S. Indian Farmer Fertilizer Co-Operative Ltd., New Delhi

ITA 2786/DEL/2015[2010-11]Status: DisposedITAT Delhi25 Mar 2022AY 2010-11

Bench: Sh. N.K.Billaiya & Sh. Anubhav Sharmaasstt. Commissioner Of Income Vs. M/S. Indian Farmer Fertilizer Tax Co-Operative Ltd. Circle -31(1), Iffco Sadan, C-1, New Delhi District Centre, Saket Place, New Delhi Pan- Aaaai0050M (Appellant) (Respondent)

Section 143(1)Section 143(2)Section 143(3)Section 14ASection 90

filed on 13.10.2010 which was revised later on 14.01.2011 showing income of Rs. 5,77,15,94,117/-. Revised return filed by the assessee was processed u/s 143(1) and thereafter case was selected for scrutiny. Statutory notice u/s 143(2)/ 141(1) of the Act were issued which

Paushak Limited, Baroda vs. ACIT, Cir-2(1)(2), Vadodara

Appeal of the assessee is partly allowed for statistical purpose

ITA 436/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad23 Mar 2022AY 2014-15

Bench: Shri P.M. Jagtap & Ms. Suchitra Kamble

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Shri S.S. Shukla, Sr. D.R
Section 115JSection 129Section 142(1)Section 143(2)Section 2Section 80Section 80I

manufacturers representative. The assessee filed return of income for assessment year 2014-15 on 26.09.2014 declaring total income of Rs.11,62,01,093/-. Revised return of income was filed on 14.03.2016 declaring total income of Rs.11,30,41,800/- under normal provisions and Rs.11,80,11,800/- under Section 115JB ... notices, the ld. A.R. of the assessee Company attended the assessment proceedings and furnished the detail. The Assessing Officer observed in the revised return of income the assessee Company claimed deduction under Section 80IA(iv)(a) of the Act of an amount of Rs.31,59,297/-. The plea taken

Kalpana Mahesh Vora(Legal Heir of Deceased Shri Mahesh A. Vora), Ahmedabad vs. The Income Tax Officer, Ward-3(1)(3), Ahmedabad

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

ITA 1189/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad23 Mar 2022AY 2014-15

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No.1189/Ahd/2018 िनधा"रण वष"/Asstt. Year: 2014-15 Kalpana Mahesh Vora, I.T.O., Legal Heir Of Deceased Vs. Ward-3(1)(3), Shri Mahesh A. Vora, Ahmedabad. (Pan: Aaupv5856H) B-101, Abhiyan Appt., Nr. Devikananadan Derasar, Naranpura, Ahmedabad-380006. (Applicant) (Respondent)

For Appellant: Shri Ankit Chokshi, A.RFor Respondent: Shri R.R. Makwana, Sr.D.R
Section 55(2)(b)

case of Goetz (India) Ltd. v. CIT 284 ITR 323/157 Taxman 1, has clearly held that A.O cannot entertain any claim otherwise than filing revised return. The valuer in the valuation report, value as on 1/4/81 has noted that the rate of ready reckoner was not in force

Ananya Ajay Mittal, Mumbai vs. DCIT CC 6 (4), Mumbai

In the result, appeals filed by the assessee are dismissed

ITA 6950/MUM/2019[2011-12]Status: HeardITAT Mumbai23 Mar 2022AY 2011-12

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Amarjit Singh, Hon'Ble

For Appellant: Shri Piyush ChhajedFor Respondent: Ms. Sailaja Rai
Section 132(1)Section 6

after the search proceedings when the; undisclosed foreign bank account of Sh. Ananya Mittal came to notice that the assessee while filing of the revised return in response to notice u/s. 153A filed his status as a non resident. • Further the assessee in his submission dated 20.12.2016 has stated that ... carefully considered. The assessee had filed the return of income in the status of an ordinary resident but subsequently, during the assessment proceedings, filed revised return as a non resident. He had given evidence of his stay and stated that he was out of India for 212 days

Dhl Logistics P.Ltd, Mumbai vs. DCIT Cir 9(3)(1), Mumbai

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

ITA 7286/MUM/2018[2014-15]Status: DisposedITAT Mumbai23 Mar 2022AY 2014-15

Bench: Shri Pramod Kumar & Shri Pavan Kumar Gadaledhl Logistics Pvt Ltd Vs. Acit – 9(3)(1) 201A, Silver Utopia, Room No. 215, Cardinal Gracias Road 2Nd Floor, Aayakar Chakala, Andheri (E) Bhavan, M.K.Road, Mumbai – 400099 Mumbai – 400020 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacm6824A Appellant .. Respondent Appellant By : Shri. Madhur Agarwal.Ar Respondent By : Dr. Yogesh Kamat.Cit.Dr Date Of Hearing 27.01.2022 Date Of Pronouncement 15.03.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm:

For Appellant: Shri. Madhur Agarwal.ARFor Respondent: Dr. Yogesh Kamat.CIT.DR
Section 143(3)Section 144C(5)Section 92D

income electronically for the A.Y 2014-15 on 29.11.2014 disclosing a total income of Rs. 94,44,89,320/-. The assessee has filed the revised return of income on 05.10.2015 with a total income of Rs.99,38,72,270/-.Subsequently, the case was selected for scrutiny and notice

The United Western Bank Ltd. (Through Successors Idbi Bank Ltd.), Mumbai vs. DCIT, Satara

In the result, all the three appeals filed by the assessee are disposed of as above

ITA 289/PUN/2010[2002-03]Status: DisposedITAT Mumbai23 Mar 2022AY 2002-03

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri C Narseh, ARFor Respondent: Shri
Section 143(3)Section 14ASection 35DSection 36(1)(vii)Section 36(1)(viia)Section 37

declaring income of Rs. 10,40,690/- has been filed by the assessee on 29-10 2002, the assessee bank has filed revised return of income filed on 31 3-2004, declaring ITA Nos. 1738/PN/2005, 289/PN/2010 & 1339/PN/2007 IDBI Bank Ltd.; AY 02-03 total income

The United Western Bank Ltd., Mumbai vs. Deputy Commissioner of Income-Tax, Jalgaon

In the result, all the three appeals filed by the assessee are disposed of as above

ITA 1339/PUN/2007[2002-03]Status: DisposedITAT Mumbai23 Mar 2022AY 2002-03

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri C Narseh, ARFor Respondent: Shri
Section 143(3)Section 14ASection 35DSection 36(1)(vii)Section 36(1)(viia)Section 37

declaring income of Rs. 10,40,690/- has been filed by the assessee on 29-10 2002, the assessee bank has filed revised return of income filed on 31 3-2004, declaring ITA Nos. 1738/PN/2005, 289/PN/2010 & 1339/PN/2007 IDBI Bank Ltd.; AY 02-03 total income

The United Western Bank Ltd., Satara vs. Additional Commissioner of Income-Tax, Satara

In the result, all the three appeals filed by the assessee are disposed of as above

ITA 1738/PUN/2005[2002-03]Status: DisposedITAT Mumbai23 Mar 2022AY 2002-03

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri C Narseh, ARFor Respondent: Shri
Section 143(3)Section 14ASection 35DSection 36(1)(vii)Section 36(1)(viia)Section 37

declaring income of Rs. 10,40,690/- has been filed by the assessee on 29-10 2002, the assessee bank has filed revised return of income filed on 31 3-2004, declaring ITA Nos. 1738/PN/2005, 289/PN/2010 & 1339/PN/2007 IDBI Bank Ltd.; AY 02-03 total income

Abhayanjaneya Health Care Private Limited, Nellore vs. ACIT Central Circle-1, Nellore

In the result, appeal of the assessee is allowed in above terms

ITA 35/HYD/2022[2019-20]Status: DisposedITAT Hyderabad22 Mar 2022AY 2019-20

Bench: Shri Aakash Deep Jain & Shri Laxmi Prasad Sahuassessment Year: 2019-2020 Abhayanjaneya Health Vs. Asst. Commissioner Of Care Pvt. Ltd., Nellore. Income-Tax, Circle – 1, Nellore Pan – Aaica 8852 D (Appellant) (Respondent) Assessee By: None Revenue By: Shri T. Sunil Goutam Date Of Hearing: 22/03/2022 Date Of Pronouncement: /03/2022

For Appellant: NoneFor Respondent: Shri T. Sunil Goutam
Section 139(1)Section 143(1)Section 36Section 36(1)(va)Section 43B

gone through the orders of revenue authorities. It is observed that the assessee had filed its return income on 10/09/2019 and filed its revised return of income on 30/11/2020 against the extended due date for filing of original return on 31/10/2019. The assessee submitted before the lower authorities that

Jt. CIT (OSD)CC-4(2), Mumbai vs. M/S. Avacado Properties and Trading (India) P. Ltd., Mumbai

ITA 547/MUM/2021[2015-16]Status: DisposedITAT Mumbai22 Mar 2022AY 2015-16

Bench: Shri M. Balaganesh & Shri Kuldip Singh

For Appellant: Shri Madhur Agrawal, A.RFor Respondent: Shri Shekhar L. Gajbhiye, D.R
Section 115JSection 132Section 139(5)Section 143(2)Section 143(3)Section 14ASection 153ASection 80I

Trading (India) Pvt. Ltd. Sr.No Particulars AY 2015- AY 2016- . 16 17 1 Date of filing original return 30.11.2015 14.10.2016 2 Date of filing revised return 27.03.2017 - Last date for issuance of notice under secrtion 143(2) of the Act (six months from the end of FY in which return ... furnished) 30.09.2017 30.09.2017 4 Date of search 30.11.2017 30.11.2017 13. Keeping in view the date of filing the original return and revised return i.e. 30.11.2015 & 27.03.2017 for A.Y. 2015-16 and 14.10.2016 for A.Y. 2016-17 respectively the notice under section 143(2) of the Act was required

Shree Ram Urban Infrastructure Limited, Mumbai vs. Assistant Commissioner of Income Tax-8(2)(1), Mumbai

Appeals are dismissed being not

ITA 4460/MUM/2017[2012-13]Status: DisposedITAT Mumbai22 Mar 2022AY 2012-13

Bench: Shri M. Balaganesh & Shri Kuldip Singhassessment Year: 2012-13

For Appellant: NoneFor Respondent: Shri Anand Mohan, D.R

accepted this concept of first layer and has calculated Capital gain and Land Cost for A.Y. 2013-14 during assessment proceedings and has filed revised return of income for A.Y. 2014-15 and A.Y. 2015- 16. Further return for A.Y. 2016-17 has also been filed applying the first layer

DCIT 2(2), Mumbai vs. State Bank of India, Mumbai

ITA 4951/MUM/2013[2005-06]Status: DisposedITAT Mumbai22 Mar 2022AY 2005-06

Bench: Shri M. Balaganesh & Shri Kuldip Singhassessment Year: 2005-06 M/S. State Bank Of India, Dcit, Financial Reporting & Circle -2(2), Taxation Dept., Mumbai 3Rd Floor, Vs. Corporate Centre, Madam Cama Road, Nariman Point, Mumbai – 400 021 Pan: Aaacs8577K (Appellant) (Respondent) Assessment Year: 2005-06 Office Of The Dcit-2(2), M/S. State Bank Of India, R.No.545, Central Office, Aayakar Bhavan, Accounts & Compliance M.K. Road, Dept., Vs. 14Th Floor, Mumbai- 400 020 Madam Cama Rd., Nariman Point, Mumbai – 400 021 Pan: Aaacs8577K (Appellant) (Respondent)

For Appellant: Shri Ketan Ved, A.RFor Respondent: Shri Anand Mohan, D.R
Section 14Section 14ASection 36Section 41(4)

learned CIT(A) erred in holding that the ground of appeal is not maintainable as no claim was made in the original / revised return or during the course of assessment proceedings. 8.1 The learned CIT(A) erred in not directing the Assessing Officer to not tax the income earned ... learned CIT(A) erred in holding that the ground of appeal is not maintainable as no claim was made in the original / revised return or during the course of assessment proceedings. 9 Each one of the above grounds of appeal is without prejudice to the other. 10 The appellant reserves

State Bank of India, Mumbai vs. DCIT Cir 2(2), Mumbai

ITA 3685/MUM/2013[2005-06]Status: DisposedITAT Mumbai22 Mar 2022AY 2005-06

Bench: Shri M. Balaganesh & Shri Kuldip Singhassessment Year: 2005-06 M/S. State Bank Of India, Dcit, Financial Reporting & Circle -2(2), Taxation Dept., Mumbai 3Rd Floor, Vs. Corporate Centre, Madam Cama Road, Nariman Point, Mumbai – 400 021 Pan: Aaacs8577K (Appellant) (Respondent) Assessment Year: 2005-06 Office Of The Dcit-2(2), M/S. State Bank Of India, R.No.545, Central Office, Aayakar Bhavan, Accounts & Compliance M.K. Road, Dept., Vs. 14Th Floor, Mumbai- 400 020 Madam Cama Rd., Nariman Point, Mumbai – 400 021 Pan: Aaacs8577K (Appellant) (Respondent)

For Appellant: Shri Ketan Ved, A.RFor Respondent: Shri Anand Mohan, D.R
Section 14Section 14ASection 36Section 41(4)

learned CIT(A) erred in holding that the ground of appeal is not maintainable as no claim was made in the original / revised return or during the course of assessment proceedings. 8.1 The learned CIT(A) erred in not directing the Assessing Officer to not tax the income earned ... learned CIT(A) erred in holding that the ground of appeal is not maintainable as no claim was made in the original / revised return or during the course of assessment proceedings. 9 Each one of the above grounds of appeal is without prejudice to the other. 10 The appellant reserves

Lions Umra Piplod Education Society, Surat vs. A.O. Circle-2, Exeption, Ahmedabad

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

ITA 197/SRT/2021[2017-18]Status: DisposedITAT Surat21 Mar 2022AY 2017-18

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Virtual Hearing In Virtual Court) Lions Umra Piplod Education Society, The Assessing Officer, Opp. Lake View Garden, C/O. Circle-2, Exemption, Vs. Shardayatan School, Piplod, Surat- Ahmedabad. 395007, Gujarat. Pan : Aaatl1289Q Appellant Respondednt

Section 10Section 10(23)(vi)Section 11Section 143(1)

under section 10(23C) and when discrepancies were pointed out by CPC, the assessee instead of correcting the mistake in the return by filling revised return, choose to assert that claim made in the return is invalid and appropriate Audit Report has been submitted. The ld. CIT(A)/ NFAC ... contention before AO/CPC. As the CPC passed the assessment order, the assesse had no opportunity to make a fresh claim by way of revised return before CPC as the process is automated. It was held by Hon'ble High Court that the assessee’s claim before appellate authority is entertainable

Mamania Family Trust, Mumbai vs. Asst CIT Cen Cir 41, Mumbai

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

ITA 308/MUM/2014[2006-07]Status: DisposedITAT Mumbai21 Mar 2022AY 2006-07

Bench: Shri A. M. Alankamony, Am & Ms. Kavitha Rajagopal, Jm आयकरअपीलसं./ I.T.A. No. 308/Mum/2014 (निर्धारणवर्ा / Assessment Year: 2006-07)

For Appellant: None byFor Respondent: Shri C. T. Mathews, Ld. DR by
Section 115WSection 139(1)Section 143(3)

dated 27.03.2012, the assessee vide letter dated 18.07.2012 requested to treat the original return filed u/s 139(1) of the Act as revised return. As the issue involved was fringe benefit tax, assessee’s original return of income as revised return of income was not accepted. The AO then insisted

Sri. Joison Kundu Kulam Johny, Bengaluru vs. Income Tax Officer, Ward- 5(3)(6), Bangalore

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

ITA 308/BANG/2021[2015-16]Status: DisposedITAT Bangalore18 Mar 2022AY 2015-16

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranassessment Year :2015-16 Shri. Joison Kundu Kulamjohny, Vs. Ito, No.11, Ephrathah Villa, 2Nd Cross, Ward – 5(3)(6), Sathya Colony, B Narayanapura Bengaluru. Dooravani Nagar, Bengaluru–560 016. Pan : Aetpj 6642 N Appellant Respondent Assessee By : Shri. Narendra Kumar Jain, Ca Revenue By : Shri. Sankar Ganesh K, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 15.03.2022 Date Of Pronouncement : 18.03.2022 O R D E R

For Appellant: Shri. Narendra Kumar Jain, CAFor Respondent: Shri. Sankar Ganesh K, JCIT(DR)(ITAT), Bengaluru
Section 131Section 132Section 132(4)Section 143(1)Section 147Section 148Section 156Section 271(1)(c)Section 274

assessee is a salaried employee with M/s SAP Labs India Pvt Ltd ('the company'). For Assessment Year 2015-16, the assessee filed revised return of income on 08.03.2016 vide acknowledgement No. 974743380080316 Page 2 of 5 declaring a total income of Rs.14,94,830/- which was arrived after claiming loss ... unearthed by the Investigation Wing of the Income Tax Department. It was submitted that without the knowledge of assessee, Mr. Nagesh Shastry has filed revised return and all requisite password, etc. was kept with him and by giving the mobile number of Mr. Nagesh Shastry only. It was submitted that

Dy. Commissioner of Income Tax, Circle-3(1), Hyderabad vs. Rain Cements Limited, Hyderabad

Accordingly. This Revenue’s cross appeal ITA 1773/Hyd/2019 is partly allowed in foregoing terms

ITA 1773/HYD/2019[2008-09]Status: DisposedITAT Hyderabad17 Mar 2022AY 2008-09

Bench: Before Shri S.S. Godara & Shri Laxmi Prasad Sahuassessment Year: 2008-09 Rain Cements Limited, Vs The Deputy Commissioner (Earlier Known As Rain Cii Of Income Tax (Appeals) – Carbon (India) Limited), 3(1), Hyderabad. Hyderabad. Pan : Aabcr8858F. (Appellant) (Respondent / Cross-Appellant) Assessment Year: 2008-09 The Deputy Commissioner Rain Cements Limited, Of Income Tax (Appeals) – (Earlier Known As Rain Cii 3(1), Hyderabad. Carbon (India) Limited), Hyderabad. Pan : Aabcr8858F. (Appellant) (Respondent / Cross-Appellant) Assessee By: Shri Nishant Thakkar Revenue By: Shri Rajendra Kumar Date Of Hearing: 10.03.2022 Date Of Pronouncement: 17.03.2022

For Appellant: Shri Nishant ThakkarFor Respondent: Shri Rajendra Kumar
Section 115JSection 143(2)Section 143(3)Section 250(6)Section 47

make it itself as per the various provisions enshrined therein. 4. The Revenue next vehemently contended that the assessee ought to have filed its revised return before the Assessing Officer in light Goetze (India) Limited Vs. CIT (2006) 284 ITR 323 (SC). We find that their lordships’ detailed decision

Rain Cements Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-3(1), Hyderabad

Accordingly. This Revenue’s cross appeal ITA 1773/Hyd/2019 is partly allowed in foregoing terms

ITA 1745/HYD/2019[2008-09]Status: DisposedITAT Hyderabad17 Mar 2022AY 2008-09

Bench: Before Shri S.S. Godara & Shri Laxmi Prasad Sahuassessment Year: 2008-09 Rain Cements Limited, Vs The Deputy Commissioner (Earlier Known As Rain Cii Of Income Tax (Appeals) – Carbon (India) Limited), 3(1), Hyderabad. Hyderabad. Pan : Aabcr8858F. (Appellant) (Respondent / Cross-Appellant) Assessment Year: 2008-09 The Deputy Commissioner Rain Cements Limited, Of Income Tax (Appeals) – (Earlier Known As Rain Cii 3(1), Hyderabad. Carbon (India) Limited), Hyderabad. Pan : Aabcr8858F. (Appellant) (Respondent / Cross-Appellant) Assessee By: Shri Nishant Thakkar Revenue By: Shri Rajendra Kumar Date Of Hearing: 10.03.2022 Date Of Pronouncement: 17.03.2022

For Appellant: Shri Nishant ThakkarFor Respondent: Shri Rajendra Kumar
Section 115JSection 143(2)Section 143(3)Section 250(6)Section 47

make it itself as per the various provisions enshrined therein. 4. The Revenue next vehemently contended that the assessee ought to have filed its revised return before the Assessing Officer in light Goetze (India) Limited Vs. CIT (2006) 284 ITR 323 (SC). We find that their lordships’ detailed decision

Tech Mahindra Ltd., Mumbai vs. ACIT, Circle - 2(3)(1), Mumbai

In the result, appeal by the assessee is allowed

ITA 6573/MUM/2019[2012-13]Status: DisposedITAT Mumbai17 Mar 2022AY 2012-13

Bench: Shri Vikas Awasthy & Shri Prashant Maharishiआअसं. 6573/मुं/2019 ("न. व. 2012-13 ) Tech Mahindra Limited, Gateway Building, Apollo Bunder, Mumbai – 400 001 Pan: Aaacm-3484-F ...... अपीलाथ" /Appellant बनाम Vs. Acit, Cir. 2(3)(1), Aaykar Bhavan, M.K.Road, Mumbai 400 020 ..... ""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By : Shri J.D.Mistri, Sr. Advocate ""तवाद" "वारा/Respondent By : Shri Rajesh Damor सुनवाई क" "त"थ/ Date Of Hearing : 20/12/2021 घोषणा क" "त"थ/ Date Of Pronouncement : 17/03/2022 आदेश/ Order Per Vikas Awasthy, Jm: 6573/Mum/2019 This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax(Appeals)-6, Mumbai [In Short 'The Cit(A)’] Dated 04/09/2019 For The Assessment Year 2012-13. 2. Shri J.D.Mistri, Sr.Advocate Appearing On Behalf Of The Assessee Submitted At The Outset That The Assessee Has Raised Additional Grounds Of 2 Appeal Assailing Jurisdiction Assumed By The Assessing Officer U/S. 147 Of The Income Tax Act,1961 ( In Short 'The Act') & Validity Of The Order Passed U/S. 143(3) R.W.S. 147 Of The Act. At This Stage He Would Be Confirning His Submissions On The Additional Grounds Raised.

For Appellant: Shri J.D.Mistri, Sr. AdvocateFor Respondent: Shri Rajesh Damor
Section 115JSection 143(3)Section 147Section 148Section 68

issued to the assessee on 07/03/2018. In response to the said notice, the assessee filed reply dated 14/03/2018 and furnished copy of revised return of income filed on 14/10/2013 declaring total income as ‘Nil’ under normal provisions and Rs.1301,87,29,580/- u/s. 115JB of the Act. Vide same letter