“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

Deep Jyoti Company, Jaipur vs. ACIT, Circle-5, Jaipur

In the result, appeal of the assessee is allowed

ITA 134/JPR/2020[2016-17]Status: DisposedITAT Jaipur02 Feb 2021AY 2016-17

Bench: The Hearing Of This Appeal.”

For Appellant: Shri S.L. Poddar (Advocate)For Respondent: Shri A.S. Nehra (Addl.CIT)

Section 143(3)Section 154Section 44A

said that fails to make the return required under sub-section (1) of section 139 and has not made a return or a revised return under sub-section (4) or subsection (5) of that section. "In the appellant case, appellant file return of income in time." Subsection

Illies Engineering India Pvt. Ltd, Mumbai vs. DCIT 2(2)(1), Mumbai

In the result, the appeal is allowed

ITA 109/MUM/2019[2012-13]Status: DisposedITAT Mumbai01 Feb 2021AY 2012-13

Bench: Shri Mahavir Singh () & Shri N.K. Pradhan () Assessment Year: 2012-13

For Appellant: Mr. Madhur Agarwal, ARFor Respondent: Mr. Michael Jerald, DR

Section 143(3)Section 271(1)(c)Section 274

which also appears to have been overlooked by the Assessing Officer before whom the tax audit report was placed. Accordingly, the assessee filed a revised return on the same day. A re-assessment was passed on the same day and the assessee then paid the tax due as well

Ashwathnarayana Singh and Co, Bellry vs. Assistant Commissioner of Income Tax Circle-1, Bellary

In the result appeal is filed by assessee for year under consideration stands allowed

ITA 522/BANG/2019[2013-14]Status: DisposedITAT Bangalore01 Feb 2021AY 2013-14

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2013-14

For Appellant: Shri Laxminiwas Sharma, C.AFor Respondent: Smt. Muzaffar Hussain, CIT (DR)

Section 143(2)Section 37

Assessee claimed Rs.9,69,00,000/- as expenditure in the original return of income and excluded the same from Sales revenue in the revised return of income contending that the same is diversion by overriding title. 8.12.3. Ld.CIT.D.R placed his reliance on certain observations made by Hon'ble Supreme

Ivorybrick Homes LLP, Bangalore vs. Assistant Commissioner of Income Tax, Circle- 1(2)(1), Bangalore

In the result appeal filed by assessee stands allowed

ITA 1846/BANG/2019[2016-17]Status: DisposedITAT Bangalore01 Feb 2021AY 2016-17

Bench: Shri. B. R. Baskaran & Smt. Beena Pillaiassessment Year : 2016-17

For Respondent: Shri C Sandeep, C.A

Section 194CSection 194JSection 40

return 4. large investment in property (Form 26QB) as compared to total income. Page 3 of 10 5. Taxable income shown in revised return is less than the taxable income shown in original return and large refund has been claimed. 3. The Ld.AO accordingly issued 143 (2) notice

JCIT (OSD), Circle-1(1)(2), Ahmedabad vs. Chiripal Industries Ltd., Ahmedabad

In the result, the appeal of the Revenue is allowed

ITA 1478/AHD/2018[2006-07]Status: DisposedITAT Ahmedabad28 Jan 2021AY 2006-07

Bench: Shri Rajpal Yadav, Vice- & Shri Amarjit Sinh"नधा"रण वष"/ Asstt.Year : 2006-07 Jcit (Osd)Circle-1(1)(2) Chiripal Industries Ld. Ahmedabad. Survey No.199/200/1 & 200/1 & 2 Vs. Saijpur Gopalpur Pirana Road Piplej, Ahmedabad. Pan : Aaacc 8513 B

For Respondent: Shri S.S. Shukla, Sr.DR

revised this return on 4.1.2008 whereby it has claimed depreciation on plant & machinery at 80% instead of 15% originally claimed. Cognizance of this revised return was not taken by the AO. He has passed assessment order on 30.12.2008 determining taxable income at Rs.3,14,59,505/-. The assessee went before ... ld.first appellate authority, who took cognizance of the revised return and held that the AO ought to have decided the issue of depreciation after taking into consideration revised return filed by the assessee. Ultimately, matter came up before the Tribunal, who remitted the matter back to the file

Omprakash Kewalram Kakwani, Mumbai vs. ACIT-C 20(2), Mumbai

In the result, appeal is allowed for statistical purposes

ITA 4134/MUM/2019[2016-17]Status: DisposedITAT Mumbai28 Jan 2021AY 2016-17

Bench: Shri Saktijit Dey

For Appellant: Shri Satyaprakash SinghFor Respondent: Shri Sanjay J. Sethi

Section 10

claim made by the assessee in the revised computation of income cannot be accepted, unless, the assessee makes such claim by filing a revised return of income. Though, the assessee challenged the aforesaid decision of the Assessing Officer before learned Commissioner (Appeals), however, he was unsuccessful. 4. I have carefully ... Assessing Officer and learned Commissioner (Appeals) have rejected assessee’s claim on the ground that such claim was not made by filing a revised return of income within the prescribed time limit. While doing so, they have relied upon the decision of the Hon'ble Supreme Court in Goetz India

Indian Express Newspapaers (Mumbai) Ltd, Mumbai vs. DCIT Cir 3(2)(1), Mumbai

The appeal of the assessee is allowed for statistical purposes in terms of our aforesaid observations

ITA 5376/MUM/2018[2013-14]Status: DisposedITAT Mumbai28 Jan 2021AY 2013-14

Bench: Shri S.Rifaur Rahman () & Shri Ravish Sood () Ita No.5376 /Mum/2018 (Assessment Year: 2013-14) Indian Express Newspapers Dy. Cit-3(2)(1) (Mumbai) Pvt. Ltd., Vs. 6Th Floor, Aayakar Bhavan, Express Towers, Nariman Point, Mumbai – 400020 Mumbai – 400021

For Appellant: Shri V. Mohan, A.RFor Respondent: Ms.Shreekala Pardeshi, D.R

Section 115JSection 143(2)Section 143(3)Section 14A

claim raised by the assessee in the course of the assessment proceedings, except for where the same had been raised by filing of a revised return of income. However, the position does not remain the same insofar the appellate authorities are concerned. As observed by the Hon’ble High Court

Il & Fs Transportation Networks Ltd., Mumbai vs. Addl.CIT-14(2) (Earlier Addl.CIT, RG. 10(1)), Mumbai

ITA 2927/MUM/2018[2010-11]Status: DisposedITAT Mumbai28 Jan 2021AY 2010-11

Bench: Shri S. Rifaur Rahman & Shri Ravish Soodita Nos.2927 & 2928/Mum/2018 (Assessment Years: 2010-11 & 2011-12) Il & Fs Transportation Networks Addl. Commissioner Of Limited, The Il & Fs Financial Income-Tax, Range -14(2), Center, Plot No.C-22, Room No. [Earlier Addl. Commissioner Of Income-Tax Vs. Range-10(1), Mumbai] 460, 4Th Floor, G Block, Bandra- Aaykar Bhavan, Maharshi Karve Kurla Complex, Bandra (E), Road, Marine Lines, Mumbai – 400 051 Mumbai – 400 020 Pan – Aabcc5460A (Appellant) (Respondent)

For Appellant: Shri Sandeep Bhalla, A.RFor Respondent: Shri Sushil Kumar Mishra, D.R

Section 14A

declined to consider the aforesaid revised claim of the assessee, for the reason, that as it was not raised on the basis of any revised return of income, the same, thus, in light of the judgment of the Hon‟ble Supreme Court in the case of Goetz (India ... Supreme Court in the case of Goetze (India) Ltd. Vs. CIT (2006) 204 CTR 182 (SC), in the absence of a revised return of income, the seeking of reduction of the disallowance that was suo motto offered by the assessee in its return of ITA Nos.2927 & 2928, 3145 & 3146/Mum/2018, A.Ys

DCIT Cen Cir 7(3), Mumbai vs. Lodha Construction (Dombivali), Mumbai

ITA 7041/MUM/2016[2009-10]Status: DisposedITAT Mumbai28 Jan 2021AY 2009-10

Bench: Shri S.Rifaur Rahman () & Shri Ravish Sood () Dcit, Central Circle-7(3) M/S Lodha Contruction Room No. 655, 6Th Floor, Vs. (Dombivali),216, Aayakar Bhavan, Shah & Nahar M.K. Road, Industrial Road, Mumbai – 400 020 Off. Dr.E.Moses Road, Worli, Mumbai – 400 018 Pan No. Aabfl3409M (Assessee) (Revenue) Assessee By : Shri Brajendra Kumar, D.R Revenue By : Ms. Aarti Sathe, A.R Date Of Hearing : 21/01/2021 Date Of Pronouncement : 28/01/2021

For Appellant: Shri Brajendra Kumar, D.RFor Respondent: Ms. Aarti Sathe, A.R

Section 143(3)Section 147Section 148Section 40Section 80Section 801Section 80I

Income Tax Act, 1961 on 27th December, 2011 at a total income of Rs.Nil. Assessee has filed return of income on 30.09.2009 and revised return on 24.11.2010 declaring total income at Rs. Nil in both the returns. The original return was filed declaring business income at Rs.21 ... whereas revised return of income was filed declaring total income at Rs.22,03,15,987/-. In both the returns, the assessee claimed deduction u/s. 8013(10). Perusal of the records reveal that for the period under consideration the assessee has shown total sales of Rs.57

Joint Commissioner of Income Tax, Special Range-7, Bangalore vs. M/S. United Breweries Limited, Bangalore

In the result, the Revenue’s appeal is dismissed

ITA 2055/BANG/2019[2009-10]Status: DisposedITAT Bangalore28 Jan 2021AY 2009-10

Bench: Shri Chandra Poojari & Smt. Beena Pillaijoint Commissioner Of Income Tax, Range 7, Bangalore. ….Appellant. Vs. M/S. United Breweries Limited, Ub Tower, Ub City, No.24, Vittalmallya Road, Bangalore-560 001. ……Respondent. Pan Aaacu 6053C Assessee By: Shri K.R. Vasudevan, Advocate. Revenue By: Shr Pradeep Kumar, Cit (D.R) Date Of Hearing : 28.01.2021. Date Of Pronouncement : 28.01.2021. O R D E R Per Shri Chandra Poojari, Am :

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Shr Pradeep Kumar, CIT (D.R)

Section 143(3)Section 194C(2)Section 244ASection 263Section 40

case are that the assessee filed the Return of Income on 25.09.2009 declaring income of Rs.78,60,19,800 and subsequently a revised return was filed on 25.02.2011 declaring income of Rs.77,35,19,800. The assessment was completed u/s. 143(3) of the Income

Inox Leisure Ltd., Baroda vs. ACIT, Circle-1(1)(2), Baroda

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 1924/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad27 Jan 2021AY 2013-14

For Appellant: Shri S.N. Soparkar, Sr. A.RFor Respondent: Shri L.P. Jain, Sr. D.R

Section 115JSection 143(2)Section 143(3)Section 391

holding that the action of the Assessing Officer in not allowing fresh claim is as per the law since the appellant had not filed revise return of Income & accordingly assesse does not deserve any relief on the account. e) In concluding that there is no error or illegality ... disallowed the claim on two grounds firstly that the claim was not made in the original return nor did the assessee file the revised return. The Jurisdictional High Court has allowed the claim of the assessee in view of the ratio laid down by Hon’ble Supreme Court

Sri. M.R.Anandaram (HUF) vs. The Assistant Commissioner of Income Tax

In the result, the appeal is disposed of

ITA/452/2016HC Karnataka27 Jan 2021

Bench: ALOK ARADHE,R. NATARAJ

Section 143(2)Section 143(3)Section 147Section 148Section 260Section 260A

return of income for the 4 Assessment Year 2007-08 on 01.11.2007 declaring an income of Rs.5,26,710/-. The assessee subsequently filed a revised return of income on 31.03.2009 declaring the agricultural income of Rs.15,00,000/- in addition to the income already declared in the original return

Blue Star Engineering & Electronics Ltd., Mumbai vs. DCIT -Circle 1(1)(1), Mumbai

The appeal stand partly allowed for statistical purposes in terms of our above order

ITA 1516/MUM/2019[2015-16]Status: DisposedITAT Mumbai25 Jan 2021AY 2015-16

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am (Hearing Through Video Conferencing Mode) आयकरअपील सं./ I.T.A. No.1516/Mum/2019 (िनधा"रण वष" / Assessment Year: 2015-16) Blue Star Engineering & Electronics Ltd. Dcit-Circle 1(1)(1) R.No.533, 5Th Floor (Successor-In-Interest Of Blue Star Design & बनाम Engineering Ltd.) Aaykar Bhawan, M.K.Road / Vs. Kasturi Building, Mohan T. Advani Chowk Mumbai – 400020 Jamshedji Tata Road, Mumbai - 400020 "थायीलेखासं./जीआइआरसं./Pan/Gir No.Aaccb-2978-D (अपीलाथ"/Appellant) (""थ" / Respondent) : Assessee By : Shri Neeraj Sheth-Ld. Ar Revenue By : Shri Tharian Ommen, Ld.Sr. Dr सुनवाई की तारीख/ : 21/01/2021 Date Of Hearing घोषणा की तारीख / : 25/01/2021 Date Of Pronouncement आदेश / O R D E R

For Appellant: Shri Neeraj Sheth-Ld. ARFor Respondent: Shri Tharian Ommen, Ld.Sr. DR

Section 115JSection 143(1)

assessee filed return of income for the year under consideration on 29/09/2015. However, the return was revised and again revised on 30/03/2017. The final revised return was processed u/s 143(1) and intimation was issued by Centralized Processing Center (CPC) on 19/06/2017 in the name of Blue Star Design ... Engineering & Electronics Limited w.e.f. 01/02/2015 as per approval of Hon’ble Bombay High Court order dated 18/12/2015. Pursuant to the same, the assessee filed revised return of income on 15/10/2016 covering transactions from the period 01/04/2014 to 31/01/2015. The return was again revised on 30/03/2017 which was processed

C S Manjunath, Tumkur vs. Income Tax Officer, Ward- 1, Tumkur

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

ITA 2640/BANG/2019[2016-17]Status: DisposedITAT Bangalore22 Jan 2021AY 2016-17

Bench: Shri George George K

For Appellant: Sri.C.S.Prahallada, CAFor Respondent: Sri.Ganesh R.Ghale, Standing Counsel

Accordingly arrived at the estimated business profit of Rs.36,02,534 instead of Rs.12,90,760 arrived in the original return. (revised returned income disclosed at Rs.14,52,485). 4. Aggrieved by the order of the Assessing Officer, the assessee preferred an appeal to the first appellate authority

ACIT Central Circle 3(4), Chennai vs. Arvind Srinivasan, Chennai

In the result, appeal filed by Revenue is dismissed

ITA 1765/CHNY/2017[2008-09]Status: DisposedITAT Chennai20 Jan 2021AY 2008-09

Bench: Shri V.Durga Rao & Shri G.Manjunathaआयकर अपील सं./I.T.A.No. 1765/Chny/2017 ("नधा"रणवष" / Assessment Year: 2008-09) The Assistant Commissioner Of Vs Mr. Arvind Srinivasan Income Tax, Central Circle-3(4), 61, Oliver Road, Mylapore, Chennai-600 034. Chennai-600 004. Pan: Adcpa0371R (अपीलाथ"/Appellant) ""यथ"/Respondent/

For Appellant: Mr. B.S.Purushotham, CAFor Respondent: 02.12.2020

Section 1Section 143(1)Section 153ASection 260ASection 40A(3)

ought to have appreciated that the same was NOT considered for the simple reasons that the total income could only be revised by filing revised return of income and not by filing a reconciliation statement as laid down by the Hon’ble Supreme Court in the case of M/s Goetz ... along with revised statement of total income, but Assessing Officer has precluded from admitting revised total income, unless such revision is made by filing revised return of income as held by 22 Hon’ble Supreme Court in the case of M/s Goetz (India) Ltd. Vs. CIT reported

Gulbano Mohd. Husain Giga, Mumbai vs. Income Tax Officer-13(1)(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 3607/MUM/2018[2009-10]Status: DisposedITAT Mumbai19 Jan 2021AY 2009-10

Bench: Shri Rajesh Kumar, Am & Shri Amarjit Singh, Jm Gulbano Mohd. Husain Giga, Vs. Income Tax Officer – Room No.11, 1St Floor 13(1)(2), Mehboob Mansion Ayakar Bhavan Near Kesar Baugh Hall Mumbai Dongro Charnull Dongri Mumbai – 400 009 Pan/Gir No.Afypg4701K (Appellant) .. (Respondent)

Section 133ASection 143(3)Section 147Section 148Section 271(1)(C)Section 271(1)(c)

01/08/2009 declaring total income of Rs.1,75,932/- which was revised subsequently on 04/08/2011 declaring total income of Rs.9,81,182/-. In the said revised return of income, the assessee disclosed the share of profit on sale consideration of Rs.16,80,250/- of sale of shop in Ahmedabad which ... served on the assessee. The assessment was completed u/s.143(3) r.w.s.147 of the Act vide order dated 30/11/2012 at Rs.10,13,680/-. In the revised return of income, the assessee has disclosed 1/4th share of sale consideration of Rs.16,80,250/- and claimed cost of improvement of Rs.1

M/S. Havells India Ltd., Delhi vs. DCIT (Ltu), New Delhi

In the result, appeal of the assessee is allowed

ITA 463/DEL/2016[2009-10]Status: DisposedITAT Delhi19 Jan 2021AY 2009-10

Bench: Sh. Anil Chaturvedi & Sh. Kuldip Singh(Through Video Conferencing)

Section 115JSection 143(2)Section 143(3)Section 154Section 40Section 92C

learned CIT (A) has erred in not adjudicating the aforesaid claim on the ground that the claim was not made by filing a revised return, without appreciating that the embargo/ prohibition contained in the case of Goetze India Limited 284 ITR 323 (SC) do not apply to the powers ... learned CIT (A) has erred in not c) adjudicating the aforesaid claim on the ground that the claim was not made by filing a revised return, without appreciating that the embargo/ prohibition contained in the case of Goetze India Limited 284 ITR 323 (SC) do not apply to the powers

M/S. Havells India Ltd., Delhi vs. DCIT (Ltu), New Delhi

In the result, appeal of the assessee is allowed

ITA 6194/DEL/2015[2009-10]Status: DisposedITAT Delhi19 Jan 2021AY 2009-10

Bench: Sh. Anil Chaturvedi & Sh. Kuldip Singh(Through Video Conferencing)

Section 115JSection 143(2)Section 143(3)Section 154Section 40Section 92C

Jv of Kiran Infra Engineers Ltd. & Eliop, Jaipur vs. Income Tax Officer, Ward-4-2, Jaipur

In the result, this appeal of the assessee is allowed

ITA 711/JPR/2019[2010-11]Status: DisposedITAT Jaipur19 Jan 2021AY 2010-11

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 711/Jp/2019 Assessment Year: 2010-11 Jv Of Kiran Infra Engineers Ltd. & Cuke I.T.O. Vs. Eliop, Ward-4(2), B-141, Road No. 9D, Vki Area, Jaipur. Jaipur. Pan No.: Aaaaj 5853 F Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Manish Agarwal (Ca) Jktlo Dh Vksj Ls@ Revenue By : Smt. Rooni Paul (Addl.Cit) Lquokbz Dh Rkjh[K@ Date Of Hearing : 15/12/2020 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 19/01/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. The Present Appeal Has Been Filed By The Assessee Against The Order Of The Ld. Cit(A), Ajmer Dated 01/03/2019 For The A.Y. 2010-11, Wherein The Assessee Has Raised Following Grounds Of Appeal: “1. On Facts & In Circumstances Of The Matter, The Ld. Cit(A) Erred In Confirming Addition Of Rs.1,18,96,853/- Made By Applying Profit Rate Of 8% On Contract Receipts Of Rs.14,87,10,667/- Arbitrarily. 1.1 That, The Ld.Cit(A) Has Further Erred In Upholding Addition By Completely Ignoring The Submission Made By Assessee & Evidences Adduced. The Addition Confirmed Are Solely Based On Conjectures & Surmises. Appellant Thus Prays That Such Addition Being Most Arbitrary, Unjust, Untenable & Bad In Law, Deserve To Be Deleted. 1.2. That, Ld. Cit(A) Has Grossly Erred In Upholding Addition Of Rs.1,18,96,853/- By Disregarding The Submission Of Assessee That Entire

For Appellant: Shri Manish Agarwal (CA)For Respondent: Smt. Rooni Paul (Addl.CIT)

Section 133(6)

assessee as tantamount to double taxation. Assessee’s predicament is discernible since the petition U/s 264 had been rejected, time to file the revised return had already expired on 31.03.2010 and the income stood taxed in the hands of M/s Kiran Infra Engineering Ltd. This left the assessee

Sri. Chinappa Venkatachalapathi, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 6(3)(1), Bangalore

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

ITA 44/BANG/2020[2012-13]Status: DisposedITAT Bangalore13 Jan 2021AY 2012-13

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

For Appellant: Sri.H.Guruswamy, ITPFor Respondent: Sri.Kannan Narayanan, JCIT-DR

Section 143(2)Section 143(3)

assessment year 2012- 2013, the return of income was filed on 17.12.2012 disclosing an income of Rs.4,39,790. The assessee filed revised return declaring total income of Rs.87,68,200. The assessment was taken up for scrutiny by issuance of notice u/s 143(2) of the I.T.Act. The assessment