“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

Principal Commissioner of Income Tax-1 vs. Boeing India Pvt. Ltd

The appeal is dismissed

ITA/586/2025HC Delhi16 Mar 2026

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

For Appellant: Mr. Debesh Panda, SSC, Ms. Zehra KhanFor Respondent: Mr. Sachit Jolly, Sr Advocate with Ms

Section 143(2)Section 144CSection 260A

MIPL. 41.3. The original return of income was not revised even though the assessment proceedings were pending. The last date for filing the revised returns was 31-3-2008, after the amalgamation order. 41.4. A search and seizure proceeding was conducted in respect of the Mahagun group, including MRPL

Principal Commissioner of Income Tax-1 vs. Boeing India Pvt. Ltd

The appeal is dismissed

ITA-586/2025HC Delhi16 Mar 2026

For Appellant: Mr. Debesh Panda, SSC, Ms. Zehra KhanFor Respondent: Mr. Sachit Jolly, Sr Advocate with Ms

Section 143(2)Section 144CSection 260A

Electronfab Engineering Pvt Ltd, Seepz Sez Mumbai vs. Income Tax Officer, Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 4828/MUM/2025[2024-25]Status: DisposedITAT Mumbai16 Mar 2026AY 2024-25

For Appellant: Shri Nishit Gandhi, Advocate (virtually appear) & Mrs. Usha DalalFor Respondent: Shri Himanshu Joshi (Sr. DR)

Section 115BSection 115JSection 139(5)Section 143(1)Section 250

amount reflected in Form No.26AS and turnover declared by the\nassessee. The assessee response the notice and rectified the defect by submitting\nthe revise return u/sec. 139(5) of the Act, but before filing the return the assessee\nfiled Form No.10IC under Rule 21AE of the Income Tax Rules ... processing\nstage. Consequently, a notice for a defective return was issued under section\n139(9) of the Act. In response, the assessee filed a revised return under section\n\n139(5) of the Act. Prior to filing the revised return, the assessee had already\nsubmitted Form No. 10IC before

Abci Infrastructures Pvt. Ltd., Kolkata, West Bengal vs. ACIT/DCIT, Central Circle 1, Guwahati, Assam

In the result, both the appeals of the assessee are allowed

ITA 419/GTY/2025[2016-17]Status: DisposedITAT Guwahati13 Mar 2026AY 2016-17

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 132(1)Section 139(1)Section 153ASection 250Section 271(1)(c)Section 274

Delhi) wherein the Hon'ble High Court has held as under: “Thus, it is clear that when the Assessing Officer has accepted the revised return filed by the assessee under section 1534. no occasion arises to refer to the previous return filed under section 139. For all purposes, including ... assessee, which incidentally gives him an opportunity to make good omission, if any, in the original return. Once the Assessing Officer accepts the revised return filed under section 153A, the original return under section 139 abates and becomes non est. The 'concealment has to be seen with reference

Abci Infrastructures Pvt. Ltd., Kolkata, West Bengal vs. ACIT/DCIT, Central Circle 1, Guwahati, Assam

In the result, both the appeals of the assessee are allowed

ITA 418/GTY/2025[2015-16]Status: DisposedITAT Guwahati13 Mar 2026AY 2015-16

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 132(1)Section 139(1)Section 153ASection 250Section 271(1)(c)Section 274

ACIT, Circle-5(1), Hyderabad vs. Ushodaya Enterprises Private Limited, Hyderabad

ITA 1782/HYD/2025[2018-19]Status: DisposedITAT Hyderabad13 Mar 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआयकर अपीलसं./I.T.A. No.1781 & 1782/Hyd/2025 (निर्धारणवर्ष/ Assessment Year: 2017-18 & 2018-19) Assistant Commissioner Of Income Tax, Circle-5(1), Hyderabad. Vs. Ushodaya Enterprises Private Limited, Hyderabad. Pan: Aaacu2690P (अपीलार्थी/ Appellant) (प्रत्यर्थी / Respondent) करदाताकाप्रतिनिधित्व/ Assessee Represented By राजस्वकाप्रतिनिधित्व/ Department Represented By सुनवाईसमाप्तहोनेकीतिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/ Date Of Pronouncement : Shri H. Srinivasulu, Advocate : Shri Mathivanan S A, Sr. Ar : 04/03/2026 : 13/03/2026 Order Per Madhusudan Sawdia, A.M.: The Captioned Appeals Are Filed By The Revenue Feeling Aggrieved By The Different Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 01/08/2025 & Dated 07/08/2025 For The Assessment Year (“A.Y.”) 2017-18 & A.Υ. 2018-19 Respectively. Since Both The Appeals Are Related To The Same Assessee, They Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Brevity.

Section 143(2)Section 143(3)Section 14ASection 14A(2)

assessee filed its return of income for Assessment Year 2017–18 on 31.10.2017, declaring a total income of Rs.234,49,73,300/-. Subsequently, a revised return of income was filed on 01.03.2019, declaring total income of Rs.221,45,69,790/-. The case of the assessee was selected for scrutiny

ACIT, Circle-5(1), Hyderabad vs. Ushodaya Enterprises Private Limited, Hyderabad

ITA 1781/HYD/2025[2017-18]Status: DisposedITAT Hyderabad13 Mar 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआयकर अपीलसं./I.T.A. No.1781 & 1782/Hyd/2025 (निर्धारणवर्ष/ Assessment Year: 2017-18 & 2018-19) Assistant Commissioner Of Vs. Ushodaya Enterprises Private Income Tax, Circle-5(1), Hyderabad. Limited, Hyderabad. Pan: Aaacu2690P (अपीलार्थी/ Appellant) (प्रत्यर्थी / Respondent) करदाताकाप्रतिनिधित्व/ Assessee Represented By राजस्वकाप्रतिनिधित्व/ Department Represented By सुनवाईसमाप्तहोनेकीतिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/ Date Of Pronouncement : Shri H. Srinivasulu, Advocate : Shri Mathivanan S A, Sr. Ar : 04/03/2026 : 13/03/2026 Order Per Madhusudan Sawdia, A.M.: The Captioned Appeals Are Filed By The Revenue Feeling Aggrieved By The Different Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 01/08/2025 & Dated 07/08/2025 For The Assessment Year (“A.Y.”) 2017-18 & A.Υ. 2018- 19 Respectively. Since Both The Appeals Are Related To The Same Assessee, They Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Brevity.

Section 143(2)Section 143(3)Section 14ASection 14A(2)

DCIT, Delhi vs. Noida Toll Bridge Company Limited, Delhi

In the result, the Revenue’s appeal stands dismissed

ITA 6174/DEL/2025[2014-15]Status: DisposedITAT Delhi13 Mar 2026AY 2014-15

Bench: Shri Mahavir Singh & Shri S. Rifaur Rahmandcit, Vs. Noida Toll Bridge Company Ltd., Room No. 419, C.R. Building, Toll Plaza, Dnd Flyway, Ip Estate, New Delhi Mayur Vihar Link Road, Delhi – 110 091 (Pan: Aaacn3498A)

For Appellant: Sh. Mahesh Kumar, CIT(DR)For Respondent: None

Section 143(3)Section 80Section 80I

audit of books of accounts and furnishing of such audit report as prescribed u/s 80IA(7) of the Act with the original or revised return of income filed on 29.11.2014 and 31.3.2016 respectively. As per details of attachment filed with the return of income as downloaded from the AST system ... provisions laid down u/s. 80-IA(7) of the Act and assessee had filed its income tax return on 29.11.2024. However, on 30.3.2016, a revised return of income was filed and the said Form 10CCB was accompanied with both the returns in order to claim deduction u/s. 80IA

DCIT, Central Circle-32, Delhi vs. Bses Yamuna Power Limited, New Delhi

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

ITA 5474/DEL/2025[2009-10]Status: DisposedITAT Delhi13 Mar 2026AY 2009-10

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumardcit, Bses Yamuna Power Limited, Central Circle-32, Room No.359, E2, Ara Centre, Delhi. Vs. Jhandewalan Extension, New Delhi-110055. [ Pan-Aabcc8569N (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Ms. Deepashree Rao, Adv. & Shri Shivam Gupta, Ca Department By Ms. Monika Singh, Cit-Dr Date Of Hearing 21.01.2026 Date Of Pronouncement 13.03.2026 O R D E R Per Vimal Kumar, Jm: The Appeal Filed By The Revenue Is Against Order Dated 23.05.2025 Of The Learned Commissioner Of Income Tax (Appeals)-30, New Delhi [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Assessment Order Dated 20.12.2016 Of Ld. Assessing Officer/Dcit, Circle-5(1), New Delhi (Hereinafter Referred To As ‘The Ld. Ao’ ) U/S 147/143(3) Of The Act For Assessment Year 2009-10. 2. Brief Facts Of The Case Are That Original Return Of Income Was Filed By Assessee On 29.09.2009 U/S 139(1) Of The Act After Adjusting Brought Forward Losses Of Dcit Vs. Bses Yamuna Power Ltd.

Section 139(1)Section 143(3)Section 147Section 148Section 250

after duly recording reasons and taking appropriate approval for doing so. In response to the notice issued, the assessee has stated that the revised return of income filed on 25.03.2011 may please be treated as return u/s 148 of the Income Tax Act, 1961. In compliance to the statutory notice

Escorts Ltd., Faridabad vs. Addl.CIT, Special Range-3, New Delhi

ITA 7394/DEL/2019[2016-17]Status: DisposedITAT Delhi13 Mar 2026AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 143(3)

claim of expenditure incurred on settlement of a corporate guarantee. 5.1 The appellant has made fresh claim of expenditure of Rs.47.64 Crore in the revised return in respect of settlement made with M/s L.S. Cables, Korea towards an arbitration award pronounced against the company and subsequently settled with this party

Payal Bansal, New Delhi vs. ITO Ward 41(5), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 1254/DEL/2019[2015-16]Status: DisposedITAT Delhi13 Mar 2026AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Years: 2015-16

Section 143(2)Section 143(3)Section 250Section 54

Income for the assessment year 2015-16 on 28-08-2015 declaring total Income of Rs. 8,16,200/-. Thereafter assessee filed a revised return on 07-09-2015 declaring total income of Rs.8,16,200/-. The total income of the assessee constitutes Income from LTCG and Income from Other

The Bank of Tokyo Mitsubishi Ufj, New Delhi vs. DCIT, Circle- 3(1)(1), International Taxation, New Delhi

ITA 7212/DEL/2017[2013-14]Status: DisposedITAT Delhi13 Mar 2026AY 2013-14

Bench: Vikas Awasthy & Shri Brajesh Kumar Singh

Section 143(2)Section 143(3)Section 144Section 144C(5)Section 44C

assessee on 31-03-2015 and income from ECBs amounting to Rs.668,07,07,663/- was also declared by the assessee. The revised return was filed at the total income of Rs.1167,35,32,730/-. The case was selected for scrutiny and notice under section ... External Commercial Borrowing (ECB) from India. The assessee had not included this income in its computation of total income in original return, however, in revised return the same was offered to tax. During the assessment proceedings the assessee claimed that this amount should be excluded from its income since

Rajkamal Agnihotri, Dehradun vs. Income Tax Officer, Dehradun

In the result, the appeal of the assessee is allowed

ITA 240/DDN/2025[2022-23]Status: DisposedITAT Dehradun12 Mar 2026AY 2022-23

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2022-23] Rajkamal Agnihotri Vs Ito Shivalik View, Lane No.3, Ward-1(1)(3) Jogiala, Ring Road, Dehradun Nathanpur, Dehradun Uttarakhand Uttarakhand -248005 Pan-Amqpa2608G Appellant Respondent Appellant By Shri K. K. Juneja, Adv. Respondent By Ms. Poonam Sharma, Cit Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 06.11.2025 By Ld. Commissioner Of Income Tax (A), Nfac, Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2021-22/10408670 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 14.03.2024 Passed U/S 143(3) R.W.S. 144B Of The Act Pertaining To Assessment Year 2022-23. 2. Brief Facts Of The Case Are That Assessee Is An Individual & Filed His Return Of Income On 28.07.2022, Declaring Total Income Of Inr 4,89,260/-. The Return Was Updated On 11.09.2023 U/S 139(8A) Of The Act, Declaring Total Income Of Inr 73,92,200/- & Paid The Taxes Alongwith The Interest Thereon. The Case Of The Assessee Was Selected For Scrutiny On The Ground That No Capital Gain Was Reported In Itr Though The Assessee Has Sold The Property Thereafter, The Assessment Was Completed U/S 143(3)/144B Of The Act Dated 14.03.2024 Wherein Income Declared In The Updated Return Filed U/S 139(8A) Of The Act Was Accepted However, Penalty Proceedings U/S 270A(1) R.W.S. 270A(8) & 270A(9)(A) Of The Act Were Initiated. The Ao Thereafter, Proceeded With Pending Penalty Proceedings & Imposed The Penalty In Terms Of The Order Dated 14.03.2024 Imposing The Penalty Of Inr 31,58,542/- U/S 270A Of The Act.

Section 139Section 143(2)Section 143(3)Section 19Section 250Section 270Section 270ASection 270A(1)Section 9

Greenwoods Govt. Officers Welfare Society in ITA No.609/Del/2023 wherein vide order dated 26.10.2023 it is held that if the income is declared in the revised return and additional tax alongwith interest is paid before the issue of show cause notice, penalty is not leviable u/s 270A of the Act. Further ... find that AO has not doubted the updated return and had completed the assessment by accepting the income declared by the assessee in the revised return filed on 11.09.2023 u/s 139(8A) of the Act. If the AO was of the opinion that such updated return could be filed

Dinesh Kumar Tiwari, Raipur vs. ITO-Ward 4(1), Raipur

In the result, appeal of the assessee is allowed

ITA 724/RPR/2025[2017-18]Status: DisposedITAT Raipur12 Mar 2026AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.724/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Dinesh Kumar Tiwari H. No.372, Dumurtalab Mohba Bazar, Tatibandh, Raipur (C.G.)-492 001 Pan: Ajgpt3287R

For Appellant: Mrs. Dimple Warylani, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 115Section 133ASection 69

already been offered to tax. This fact was admitted by the Ld. Sr. DR. 5. The A.O had also doubted the various revised returns that were filed by the assessee and the same findings were upheld by the Ld. CIT(Appeals) /NFAC. However, the Revenue had failed to point ... they have stated that such filing of revised returns are an afterthought and concocted story to cover up the claim of cash payment since all the revised returns filed were valid returns as per law and the Revenue had also not brought on record any evidence to corroborate the findings

DCIT, Circle-3(4), Mumbai vs. Glenmark Pharmaceuticals Limited, Mumbai

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3991/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-17

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR

Section 143(3)Section 35Section 41(1)Section 801C

under section 32AC of the Income Tax Act, 1961, made by the assessee through a revised computation of income during assessment proceedings, without a revised return of income as mandated under section139(5) of the Act, and in disregard of the binding decision of the Hon'ble Supreme Court ... regarding the claim of excise duty exemption being capital receipts, when this claim was made neither in the return of income nor in the revised return of income filed by assessee? 17 "Whether, on the facts and in the circumstances of the case, the CIT(A) erred in treating

DCIT, Circle-3(4), Mumbai vs. Glenmark Pharmaceuticals Limited, Mumbai

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3971/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Mar 2026AY 2015-16

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR

Section 143(3)Section 35Section 41(1)Section 801C

Ericsson India Global Services Pvt Ltd, New Delhi vs. ACIT Spl. Range 3, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 2367/DEL/2019[2013-14]Status: DisposedITAT Delhi12 Mar 2026AY 2013-14

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singhassessment Year : 2013-14

For Appellant: Shri Paras S. Savla, AdvocateFor Respondent: Shri M.S. Nethrapal, CIT-DR

Section 143(1)Section 143(13)Section 143(2)Section 143(3)Section 144C(3)Section 234BSection 234CSection 254(2)Section 92C

declaring total income of Rs.302,63,71,210/- claiming Foreign Tax Credit (FTC) of Rs.1,60,87,785/-. Thereafter, the assessee filed revised return of income on 31st March, 2015 to enhance FTC claim to Rs.3,60,88,761/-. In assessment proceedings u/s143(2) of the Act, a reference

Logics Poweramr Private Limited, Delhi vs. Asst Director of Income Tax, Bengaluru

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

ITA 6641/DEL/2025[2021-22]Status: DisposedITAT Delhi11 Mar 2026AY 2021-22

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2021-22 Logics Poweramr Private Vs. Asstt. Director Of Income Limited Tax, 1St Floor, Prestige Alpha No. 7, Sarswati Bhawan 1/4 Lalita Park, Laxmi Nagar 48/1, 48/2, East Delhi Laxmi Nagar Beratenaagrahara Begur, Delhi-110092 Hosur Rd. Uttarahalli Hobli, Pan No.Aadcl3204D Bangalore-560100 (Appellant) (Respondent)

Section 115JSection 143(1)Section 143(1)(a)Section 80I

further offered income u/s 11 5JB at Rs. 5,34,33,460/-. The appellant further filed a revised return on 28.12.2016 declaring an income of Rs. 5,45,170/- after revising the deduction u/ s. 801A to Rs. 19,18,68,986/- u/s. 801A of the Income ... income u/s 115JB at Rs. ,5,09,10,210/- . The revised return was processed u/s 143(1) on 20.08.2017 which resulted in the disallowance u/s 801A(4) of Rs. 19,18,68,986/-, thus resulting in the income of Rs. 19,24,14,160/- (after rounding of). The appellant filed

Asst. Commissioner of Income Tax, Mumbai vs. Reliance Retail Limited, Mumbai

In the result, the appeal filed by the Revenue is dismissed, whereas the appeal filed by the assessee is partly allowed

ITA 4244/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Mar 2026AY 2019-20

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 135Section 143(3)Section 144BSection 14ASection 250Section 37(1)Section 80GSection 80JSection 92C

filed its original return of income for Assessment Year 2019–20 on 30.11.2019 declaring total income of Rs. 4556,20,76,520/-. Subsequently, a revised return of income was filed on 29.07.2020 declaring total income of Rs. 4567,49,77,390/-. The return of income was selected for scrutiny assessment ... without proper verification of the relevant details. It was contended that the assessee had enhanced the claim of deduction under section 80JJAA in the revised return of income, however, the corresponding audit report in Form No. 10DA was not revised. According to the learned DR, the claim made

Reliance Retail Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 8(1)(1), Mumbai

ITA 3510/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Mar 2026AY 2019-20

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

Section 135Section 143(3)Section 144BSection 14ASection 250Section 37(1)Section 80GSection 80JSection 92C