“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-2(2)(1), Mumbai vs. Yes Bank Limited, Mumbai

In the result, appeals of the revenue for AY 2011-12 to 2013-14 are dismissed

ITA 5413/MUM/2025[2013-14]Status: DisposedITAT Mumbai11 Nov 2025AY 2013-14

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Appellant: Shri. Swapnil Choudhary Sr. AR

Section 143(3)Section 250Section 271(1)(c)Section 35DSection 40

perused the relevant materials on record. The reasons for our decisions are given below. The appellant is a banking company. It filed its revised return of income for the AY 2010-11 on March 30, 2012 declaring total income at Rs. 7,90,10,18,157/-. As mentioned earlier

DCIT-2(2)(1), Mumbai vs. Yes Bank Limited, Mumbai

In the result, appeals of the revenue for AY 2011-12 to 2013-14 are dismissed

ITA 5412/MUM/2025[2012-13]Status: DisposedITAT Mumbai11 Nov 2025AY 2012-13

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Appellant: Shri. Swapnil Choudhary Sr. AR

Section 143(3)Section 250Section 271(1)(c)Section 35DSection 40

DCIT-2(2)(1), Mumbai vs. Yes Bank Limited, Mumbai

In the result, appeals of the revenue for AY 2011-12 to 2013-14 are dismissed

ITA 5411/MUM/2025[2011-12]Status: DisposedITAT Mumbai11 Nov 2025AY 2011-12

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Appellant: Shri. Swapnil Choudhary Sr. AR

Section 143(3)Section 250Section 271(1)(c)Section 35DSection 40

Shore Dwellings Private Limited, Bengaluru vs. Income Tax Officer, Ward-6(1)(1), Bangalore

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

ITA 1263/BANG/2025[2023-24]Status: DisposedITAT Bangalore10 Nov 2025AY 2023-24

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessment Year : 2023-24

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Smt. Srinandini Das, CIT-DR

Section 143(1)Section 201Section 40

brief facts of the case are that the assessee filed their return of income on 31/10/2023. Thereafter, filed a revised return of income on 29/12/2023 and declared a loss of Rs. 211,32,58,126/-. Along with the said return, the assessee also filed the tax audit report in form

DCIT-CC-8(4), Mumbai vs. Savita Oil Technologies Limited, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 4292/MUM/2025[2018-19]Status: DisposedITAT Mumbai10 Nov 2025AY 2018-19

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2018-19 Dcit-Cc-8(4), Savita Oil Technologies Limited Mumbai 66-67 Nariman Bhavan, Vs. Nariman Point, Mumbai 400021, Pan: Aaacs7934A (Appellant) (Respondent) Present For: Assessee : Shri Yogesh Thar & Shri Chaitanya Joshi, Cas Revenue : Shri Rajesh Kumar Yadav, Cit Dr Date Of Hearing : 13.08.2025 Date Of Pronouncement : 10.11.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue Is Against The Order Of Cit (A) 50, Mumbai, Vide Order No. Itba/Apl/S/250/2025-26/1075632908(1), Dated 15.04.2025 Passed Against The Assessment Order By Acit,Cc- 8(4), Mumbai, U/S.143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 24.08.2021 For Ay 2018-19. 2. Grounds Taken By The Revenue Are Reproduced As Under: “1. Whether On The Facts & In The Circumstances Of The Case, The Hon'Ble Cit(A) Was Justified In Law In Allowing Deduction Under Section 80-Ia(4) Of The Income- Tax Act, 1961, Without Adjusting The Losses Incurred By The Eligible Undertaking Prior To The Initial Assessment Year, Contrary To The Provisions Of Section 80-Ia(S)? 2. Whether The Hon'Ble Cit(A) Was Correct In Law In Relying Upon Cbdt Circular No. 1/2016 & The Decision Of The Hon'Ble Madras High Court In The Case Of Vcllayudhaswamy Spinning Mills Pvt. Ltd. (340 Itr 477) When There Exist Contrary Binding Judicial Precedents Mandating That Losses Of Earlier Years, Even

For Appellant: Shri Yogesh Thar and Shri Chaitanya Joshi, CAsFor Respondent: Shri Rajesh Kumar Yadav, CIT DR

Section 143(3)Section 37Section 80Section 80GSection 80I

decision in the case of Goetze India Ltd. vs CIT. In this regard, assessee further submitted that it could not file the revised return since the time limit for filing the same was already lapsed. Relying on the decision of Hon'ble Bombay High Court in the case of Siva ... ought to have considered the claim which was denied as according to ld. Assessing Officer, the same was not included in the revised return. In the first appeal, assessee reiterated its submission and claimed it as allowable deduction u/s.80G by placing reliance on the decision of Prithvi Brokers (supra). Further

All India Fine Art and Crafts Society, New Delhi vs. ITO, Ward Expempt 1(1), Delhi, New Delhi

In the result, appeal of assessee in ITA No

ITA 3730/DEL/2024[2017-18]Status: DisposedITAT Delhi10 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, AdvFor Respondent: Shri Rajesh Mahajan, Sr. DR

Section 11Section 11(3)Section 143(3)Section 250Section 270A

assessee filed its original return of income for A.Y. 2017-18 on 31/10/2017 declaring Rs. NIL income. The assessee filed revised return of income on 13/02/2019 declaring Rs. 48,95,770/- income. The case was selected through CASS. 7. In the course of assessment proceedings, the Assessing Officer show caused ... further held that the assessee has not clarified as to whether the Form No.9A was filed with the original return or with the revised return nor a copy of the Form No.9A has been filed during the appellate proceedings for verification as the AO does not seem to have examined

DCIT Circle 4(2), New Delhi vs. Canon India Pvt. Ltd., New Delhi

In the result, to sum up and conclude:

ITA 1038/DEL/2023[2005-06]Status: DisposedITAT Delhi10 Nov 2025AY 2005-06

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Vijay B. Basanta, CIT-DR

Section 10ASection 143(3)Section 254Section 92C

erred in not granting complete credit of taxes withheld at source (by the deductors in India) claimed in the revised return of income amounting to RS 23,90,314/-.” Page 3 of 38 ITA No. 5855/DEL/2021 [A.Y. 2003-04] CO No. 04/DEL/2025 ITA No. 1038/DEL/2023 [A.Y. 2005-06] Canon India ... withheld in Japan, out of which the assessee claimed credit of Rs. 1,02,768 only in its revised return of income. 23. We further note that the grant of interest u/s 244A, during the impugned assessment year 2005-06, is governed by the Direct Tax Laws (Amendment

Canon India Pvt. Ltd, Gurugram vs. Neac, Delhi

In the result, to sum up and conclude:

ITA 585/DEL/2021[2003-04]Status: DisposedITAT Delhi10 Nov 2025AY 2003-04

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Vijay B. Basanta, CIT-DR

Section 10ASection 143(3)Section 254Section 92C

Jain Babulal Champatlal, Vijayawada vs. Income Tax Officer, Ward 2(1), Vijayawada

In the result, both the appeals filed by the assessee are 9

ITA 401/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam07 Nov 2025AY 2018-19

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.400 & 401/Viz/2025 (निर्धारण वर्ा/ Assessment Year:2018-19) Vs. Jain Babulal Champatlal Income Tax Officer – Ward – 2(1) Cr Building, 1St Floor Annex 40-1-155, Lgf Mg Road, Vijayawada – 520002 Ripples Mall, M.G. Road Andhra Pradesh Vijayawada-520010 Andhra Pradesh [Pan:Aefpc1220F]

Section 10Section 143(2)Section 143(3)Section 270ASection 57

Constructions, filed his return of income for the A.Y. 2018-19 on 25.07.2018 admitting a total income of Rs.51,17,260/-. Thereafter, assessee filed revised return of income on 08.08.2018 with total taxable income at Rs.45,32,580/-. Subsequently, the case was selected for complete scrutiny under e-assessment scheme ... verifying “reduction of Income in Revised Return & Claim of Refund”. Accordingly, statutory notices under section 143(2) and 142(1) of the Act were issued and served on the assessee. In response, assessee furnished the information as called for. During the course of scrutiny proceedings, Ld. AO noticed that assessee

Jain Babulal Champatlal, Vijayawada vs. Income Tax Officer, Ward 2(1), Vijayawada

In the result, both the appeals filed by the assessee are 9

ITA 400/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam07 Nov 2025AY 2018-19

Section 10Section 143(2)Section 143(3)Section 270ASection 57

DCIT, Circle 4(2), New Delhi vs. Ms Communique Marketing Solutions Pvt Ltd, New Delhi

In the result, the appeal of Revenue is dismissed and cross-objection of Assessee is allowed

ITA 4762/DEL/2024[2017-18]Status: DisposedITAT Delhi07 Nov 2025AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2017-18 Deputy Commissioner Of Income Vs. Ms Commmunique Marketing Tax, Circle 4(2), Solutions (P) Ltd., 5407, Arya Samaj New Delhi. Road, Karol Bagh, New Delhi-110005 Pan :Aaccc3432F (Appellant) (Respondent)

Section 115Section 115BSection 142(1)Section 143(1)Section 143(2)Section 250Section 37Section 68

filed return of income on 04.11.2017 showing income of Rs. 9,91,34,394/-. The return was processed under Section 143(1) Act. The revised return of the assessee was selected by CASS for Limited Scrutiny for assessment year 2017-18 to verify two issues i.e. (i) Bonus or Commission

Ratnadeep Infrastructure Private Limited, Ahmedabad vs. Income Tax Officer, Old Ward 3(1)(3), New Ward 3(1)(2), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1491/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad06 Nov 2025AY 2012-13

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal1. आयकर अपील सं /Ita No.1490/Ahd/2025, Asst.Year 2011-12 2. आयकर अपील सं /Ita No.1491/Ahd/2025, Asst.Year 2012-13 Ratnadeep Infrastructure The Income Tax Officer बनाम/ Private Limited Old Ward-3(1)(3) V/S. 126, 1St Floor New 3 (1) (2) Neelam Shopping Center Krishna Nagar Chowk Ahmedabad – 382 346 "थायी लेखा सं./Pan: Aaecr 5728 F (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Chetan Agarwal, Ar Revenue By : Shri Abhijit, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 16/09/2025 घोषणा की तारीख /Date Of Pronouncement: 06/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Of Even Date 01/07/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Years (Ays) 2011-2012 & 2012-13. 2. The Assessee Has Raised The Following Grounds Of Appeal In Ita No.1490/Ahd/2025 For Ay 2011-12:

For Appellant: Shri Chetan Agarwal, ARFor Respondent: Shri Abhijit, Sr.DR

Section 131Section 143(1)Section 143(3)Section 147Section 250Section 271(1)(c)Section 69

medical reasons. The Assessing Officer, observing that the statement stood unretracted and corroborated by the high stamp duty valuation and the seller’s revised return showing the same consideration, he completed the assessment under section 143(3) read with section 147 of the Act on 24.12.2018, determining the total income

Ratnadeep Infrastructure Private Limited, Ahmedabad vs. Income Tax Officer, Old Ward 3(1)(3) New Ward3(1)(2)), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1490/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad06 Nov 2025AY 2011-12

For Appellant: Shri Chetan Agarwal, ARFor Respondent: Shri Abhijit, Sr.DR

Section 131Section 143(1)Section 143(3)Section 147Section 250Section 271(1)(c)Section 69

The Farmer Bank Staff Co-Operative Society Ltd, Fort, Mumbai vs. Income Tax Officer, Piramal Chambers

ITA 5686/MUM/2025[2018-19]Status: DisposedITAT Mumbai06 Nov 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Sushant Alme, Ld. A.RFor Respondent: Ms. Kavitha Kaushik, Ld. Sr. D.R

Section 119(2)(b)Section 139Section 139(1)Section 143(3)Section 147Section 250Section 80ASection 80PSection 80P(2)(a)Section 80P(2)(d)

first appeal before the Ld. Commissioner, however, could not get any relief, as the Ld. Commissioner by observing that the Assessee never filed a revised return u/s 139 of the Act to claim correct deduction of Rs.37,85,168/- u/s 80P(2)(a)(i) of the Act. Original return

Foster Wheels (Gb) Limited, Chennai vs. DCIT, International Tax Circle 1(1), Chennai

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

ITA 927/CHNY/2024[2018-19]Status: DisposedITAT Chennai04 Nov 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.Ashik Shah, CAFor Respondent: Mr.Nathala Ravi Babu, CIT

Section 133ASection 143(3)Section 245M

assessee during the course of assessment proceedings and allowed the claim for deduction expenditure made through such revised computation and not through a revised return of income? 2. Whether under the facts and circumstances of the case, the Income Tax Appellate Tribunal was right in holding that the assessee

Mirae Asset Capital Markets (India) Private Limited, Mumbai vs. Income Tax Officer, Ward 4(3)(1), Mumbai

The appeal of the assessee is allowed

ITA 2099/MUM/2025[2020-21]Status: DisposedITAT Mumbai04 Nov 2025AY 2020-21

Bench: Shri Amit Shukla, Jm& Ms Padmavathy S, Am

For Appellant: Shri Pratik Poddar, & Shreyas SardesaiFor Respondent: 14.10.2025

Section 143(1)Section 143(1)(a)Section 14ASection 234CSection 250

return of income for AY 2020-21 on 15.02.2021 declaring a total income of Rs. 1,30,88,02,420/-. The assessee also files revised return of income on 31.03.2021. The revised return filed by the assessee was processed by Central Processing Centre

State Bank of India, Mumbai vs. The Assistant Commissioner of Income Tax – 2(2)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 1377/MUM/2025[2018-19]Status: DisposedITAT Mumbai04 Nov 2025AY 2018-19

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Appellant: Shri Ninad PatadeFor Respondent: Shri. Arun Kanti Datta- CIT DR

Section 143(3)Section 147Section 148Section 148ASection 151Section 250Section 37(1)Section 40

filed the return of income for AY 2018-19 on 28.11.2018 declaring total loss of Rs. 26225,93,41,754/-. The assessee filed a revised return of income declaring a loss of Rs. 28209,28,60,931/-. The return was selected for scrutiny and the statutory notices were duly served

Assistant Commissioner of Income Tax, Circle-49(1), New Delhi vs. Suresh Kumar Goyal, New Delhi

The appeal is allowed

ITA 3173/DEL/2023[2018-19]Status: DisposedITAT Delhi04 Nov 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 2018-19 Vs. Sh. Suresh Kumar Goyal, Acit, Circle-49(1), A-1/102, Ground Floor, New Delhi Janak Puri, Delhi Pan: Aaapg4996R (Appellant) (Respondent) Assessee By None Department By Sh. Manish Gupta, Sr. Dr

Section 143(3)Section 68Section 80G

Goyal Iron & Steel Traders. Assessee filed his original Return of Income on 31.10.2018 declaring total income of Rs. 22,79,120/- and a revised Return of Income was also filed on 30.10.2018 declaring total income of Rs. 21,79,120/-. In revised return, the assessee claimed 50% deduction

Manojbhai C. Kamdar, Rajkot vs. Income Tax Officer, Income Tax Office

In the result, the appeal of the assessee is allowed

ITA 572/RJT/2025[2024-25]Status: DisposedITAT Rajkot03 Nov 2025AY 2024-25

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.572/Rjt/2025 िनधा"रणवष" / Assessment Year: (2024-25) Manojbhai C. Kamdar, Vs. Ito, Ward-1(1)(1), A-47, Aalap Green City, Raiya Aayakar Bhavan, Race Course Ring Road, Rajkot (Gujarat) - 360007 Road, Rajkot (Gujarat) – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adgpk8679J (Appellant) (Respondent) Appellant By : Shri R. D. Lalchandani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr

For Appellant: Shri R. D. Lalchandani, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 111ASection 115BSection 143(1)Section 250Section 87A

express restriction in section 87A or section 111A.” 5.6 The undisputed facts of the case are that the assessee, a resident individual, filed a revised return of income for A.Y. 2024–25 declaring total income of Rs.6,76,402/-, comprising short-term capital gain on listed equity shares taxable

Kalpesh Kumar Ramanlal Shah, Davangere vs. ACIT, Circle-1(1), Davangere

In the result, the Assessee’s appeal is allowed

ITA 1169/BANG/2025[2017-18]Status: DisposedITAT Bangalore31 Oct 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Waseem Ahmedassessment Year : 2017-18

For Appellant: Ms. Sunaina Bhatia, CAFor Respondent: Shri Balusamy N., JCIT-DR

Section 11Section 119Section 143(1)Section 250Section 80I

dated 19/01/2019 u/s. 143(1) of the Act {Page 37 of the paper book}. 3. The Assessee subsequently by realizing its mistake filed his revised return of income on 24/03/2018 within the due date, which was processed vide intimation/order dated 19/03/2019, whereby the deduction claimed to the tune ... return of income, within the time limit as prescribed for that purpose. It is also a fact the at the time of processing of revised return of income, Form 10CCB was made available before the CPC/Assessing Officer, who somehow without taking into Page 3 of 7 consideration such fact, made