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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.

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.

Pr. CIT v. Ankit Metal & Power Ltd.
109 Taxmann.com 93 · 2019 · High Court
77
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
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

Prabha Multitrade Private Limited, Mumbai vs. Assistant Commissioner of Income Tax - Central Circle 46, Mumbai

In the result, appeal of the assessee is dismissed

ITA 4320/MUM/2018[2010-11]Status: DisposedITAT Mumbai13 Nov 2019AY 2010-11

Bench: Shri R.C.Sharma, Am M/S. Prabha Multitrade Pvt. Vs. The Asst. Commissioner Ltd., Of Income Tax Block H, Shri Sadashiv Chs Central Circle – 46, Ltd., 6Th Road Mumbai Santacruz (E) Mumbai – 400 055 Pan/Gir No.Aafcp0813N (Appellant) .. (Respondent) Assessee By Shri Mukesh Chokshi Revenue By Shri Akthar H Ansari Date Of Hearing 06/11/2019 Date Of Pronouncement 13/11/2019 आदेश / O R D E R Per: R.C. Sharma, A.M. This Is An Appeal Filed By The Assessee Against The Order Of Cit(A)—22, Mumbai In Appeal No. Cit(A)-22/It/242/2014-15 Dated 05/04/2018 In The Matter Of Order Passed U/S.143(3) Of The Income Tax Act, 1961. 2. The Grievance Of The Assessee Revolves Around Addition Of 2% Commission Of Alleged Receipt As Per The Bank Statement. 3. I Have Considered Rival Contentions & Found That Ao Has Estimated Income At 0.15% On Total Receipt Of Rs.8,40,75,293/-. It Was Contention Of Assessee Before The Ao & Cit(A) That Receipt Was Only To The Tune Of Rs.4,70,70,093/-. Even Before Me, There Was Contention Of Ld. Ar That Rs.8,40,75,293/- Has Been Wrongly Estimated By The Ao. I

Section 143(3)Section 271

Thus, assessee had ample time at its disposal so as to rectify and file a revised return or point out the same at the time of scrutiny assessment. (iv) No evidence in support of their contention of higher turn over adopted by mistake has been submitted. (v) The principle

Buro Happold Limited, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-1(3)(2), Mumbai

The appeal stands allowed for statistical purposes

ITA 7111/MUM/2017[2014-15]Status: DisposedITAT Mumbai13 Nov 2019AY 2014-15

Bench: Shri Saktijit Dey, Jm & Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri Vijay Mehta-Ld. ARFor Respondent: Shri O.P. Meena-Ld. DR
Section 143(3)Section 144C(5)Section 234B

assessee finally declared an income of Rs.120.58 Lacs on account of consulting and engineering services. The assessment was framed on the basis of latest revised return filed by the assessee on 4 Buro Happold Ltd. Assessment Year-2014-15 31/03/2016. The assessee is stated to be an entity registered

M/S. Overseas Logistics Pvt. Ltd., Delhi vs. DCIT, New Delhi

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

ITA 534/DEL/2017[2013-14]Status: DisposedITAT Delhi13 Nov 2019AY 2013-14

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Ms Rinku Singh, Sr.DR

even after knowing the defect in the service-tax return, the assessee did not take any steps for rectification or filing of the revised return and, therefore, the plea taken by the assessee is not acceptable. 8. We have gone through the record in the light of the submissions made

ACIT, New Delhi vs. M/S. Dhanuka Agritech Ltd., Delhi

In the result, appeal of the Revenue dismissed

ITA 3837/DEL/2016[2011-12]Status: DisposedITAT Delhi13 Nov 2019AY 2011-12

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: Shri S.S. Nager, C.AFor Respondent: Ms. Rakhi Bimal, Sr. D.R
Section 115JSection 155J

section 115JB of the I.T. Act, is not allowable since it is in the nature of fresh claim. It can only be raised through revised return. The A.O. relied upon Judgment of Hon’ble Supreme Court in the case of Commissioner of Income Tax vs. Goetze (India ... same contention. It was also submitted that appellate authorities have power to consider the claim of assessee which was not raised in revised return. The assessee relied upon Judgment of Hon’ble Delhi High Court in the case of Commissioner of Income Tax vs., Jai Parabolic 6 ITA.No.3837/Del./2016

ACIT Non Corporate Circle 20(1), Chennai vs. Shri Balaji Communications, Chennai

In the result, cross objection filed by the assessee is allowed

ITA 2073/CHNY/2018[2008-09]Status: DisposedITAT Chennai11 Nov 2019AY 2008-09

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकर अपील सं./Ita No.2073/Chny/2018 "नधा"रण वष" /Assessment Year : 2008-09 Assistant Commissioner Of M/S. Shri Balaji Communications, Vs. Income Tax, No.3/6, Mgr Salai Non Corporate Circle-20(1), Vijayaraghavapuram, Chennai – 600 034 Chennai – 600 093. [Pan : Abifs 0605 A] (अपीलाथ"/Appellant) (""यथ"/Respondent) & C.O. No.9/Chny/2019 आयकर अपील सं./Ita No.2073/Chny/2018 "नधा"रण वष" /Assessment Year : 2008-2009 M/S. Shri Balaji Communications Assistant Commissioner Of Income Tax, No.3/6, M.G.R. Salai, V. Non Corporate Circle – 20(1) Vijayaraghavapuram Aayakar Bhavan Chennai – 600 093. 121, M. G. Road, Chennai – 600 034 Pan : [Abifs 0605 A] (अपीलाथ"/Appellant) (""यथ"/Respondent) : राज" की ओर से /Revenue By Shri A.V.R. Sreenivasan, Jcit : Shri Philip George & िनधा"रती की ओर से /Assessee By Shri D. Palanivel, Advocates

Section 143(3)Section 147Section 148Section 32(1)(ii)

Income Tax Appellate Tribunal restored the addition made u/s.40(a)(ia). 3. It was noticed that in assessment: (a) The revised income as per revised return of Rs.1,27,12,850/- was not added to the total income. While completing the original assessment. (b) The film rights purchases

Unique Properties & Securities Private Limited, Mumbai vs. Assistant Commissioner - Central Circle 38, Mumbai

In the result, the appeal is allowed for statistical purposes

ITA 66/MUM/2018[2011-12]Status: DisposedITAT Mumbai08 Nov 2019AY 2011-12

Bench: Shri Saktijit Dey () & Shri N.K. Pradhan () Assessment Year: 2011-12 Unique Properties & Securities Private Assistant Commissioner-Central Circle Limited, 4Th Floor, Malhotra House, Opp. Vs. 38, [Now Dcit Central Circle 6(3)], 19Th Gpo, Fort, Mumbai-400001. Floor, Air India Building, Nariman Point, Mumbai-400021. Pan No. Aaacu0702G Appellant Respondent

For Appellant: Shri Prayag Jha - ARFor Respondent: Shri D.G. Pansari - DR
Section 143(3)Section 54E

company filed its return of income for the AY 2011-12 on 14.10.2010 declaring total income of Rs.4,59,836/-. Thereafter it filed a revised return of income on 23.11.2011 declaring total income of Rs.2,00,292/-. During the year under consideration, the appellant had sold a property, land admeasuring

DCIT- 5(2)(1), Mumbai vs. Jsw Infrastructure Ltd., Mumbai

ITA 3708/MUM/2018[2014-15]Status: DisposedITAT Mumbai08 Nov 2019AY 2014-15

Bench: Shri Vikas Awasthy & Shri G. Manjunatha

Section 115JSection 139(1)Section 139(5)Section 14ASection 80ASection 80A(5)Section 80I

respect of profits of its Goa undertaking in original return filed u/s 139(1) of the I.T.Act, 1961. Subsequently, the assesee has filed revised return u/s 139(5) and has claimed additional deduction u/s 80IA of the Act, for Rs. 11,28,18,375/-, in M/s. JSW Infrastructure Ltd. respect ... 80IA of Rs.11,28,18,375/- in respect of profits and gains of Jaigarh undertaking and such claim has been made in the revised return without making any claim in original return therefore, he opined that deduction claimed u/s 80IA is not available in view of specific provision of section

JCIT (OSD) Circle-8(3)(1), Mumbai vs. Tata Aia Life Insurance Co, . Ltd, Mumbai

In the result, the appeal of the Revenue is dismissed and the appeal of the assessee is allowed

ITA 1482/MUM/2018[2014-15]Status: DisposedITAT Mumbai08 Nov 2019AY 2014-15

Bench: Shri Mahavir Singh & Shri Rajesh Kumarassessment Year: 2014-15

For Appellant: Shri Nishant Thakkar, A.RFor Respondent: Shri R. Manjunatha Swamy, D.R
Section 10(34)Section 44

respectively on the basis that the deduction would reduce the assessed income below the income disclosed in the revised return of income.” 13. The assessee has also raised following additional grounds which is as under : “The CIT(A) erred in holding the exemption under section 10(34) is allowable ... permissible (the surplus as per Old Form I comes to Rs 3,80,60,05,935 and the income as per the revised return of income is Rs 4,53,28,55,247) in view of the decision of Hon'ble Mumbai High Court in the case

M/S Hydel Construction (P) Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is allowed

ITA 2170/DEL/2016[2012-13]Status: DisposedITAT Delhi07 Nov 2019AY 2012-13

Bench: Sh. Bhavnesh Sainidr. B. R. R. Kumarita No. 2170/Del/2016 : Asstt. Year : 2012-13 Hydel Construction (P) Ltd. Vs Dcit C-287, Defence Colony, Circle 11(2) New Delhi. New Delhi. (Appellant) (Respondent) Pan No. Aaach3012Q Assessee By : Sh. Alok Periwal Revenue By : Sh. Deepak Garg, Sr. Dr

For Appellant: Sh. Alok PeriwalFor Respondent: Sh. Deepak Garg, Sr. DR

thought as this fact was not reported by the auditor. Further, it was held that the loss should have been claimed by filling of revised return for the AY 2012-13 and simply filing a statement no deduction or claim can be entertainment as held by the Hon’ble Supreme

Income Tax Officer (It)-4(1)(1), Mumbai vs. Mr. Prabhakar Raghavendra Rao, Mumbai

In the result, appeal of the revenue is dismissed

ITA 3985/MUM/2018[2014-15]Status: DisposedITAT Mumbai06 Nov 2019AY 2014-15

Bench: Shri M.Balaganesh, Am & Shri Amarjit Singh, Jm Income Tax Officer (Intl. Vs. Mr. Prabhakar Raghavendra Tax) – 4(1)(1), Rao 1729, Air India Building Flat No.602, Palm Paradise Nariman Point Palm Beach Road Mumbai – 400 021 Sector-17, Sanpada, Navi Mumbai – 400 705 Pan/Gir No. Aafpr3259K (Appellant) .. (Respondent)

Section 119(2)(b)Section 143Section 143(3)Section 43B

also observed in his order that in any case, this claim of exemption was not made by the assessee even in the revised return of income filed on 25/03/2016 and hence, the claim of the assessee could not be entertained. 4 Shri Prabhakar Raghavrao Rao 3.1. The assessee before ... pleaded that since the time limit for filing the revised return of income had expired, the claim of non- taxability of non-compete and non-solicitation fees received from BVCPL was made by the assessee by filing a letter dated 03/10/2016 before the ld. AO during the course of assessment

Sony Mobile Communications International Ab (India Branch Office), New Delhi vs. DCIT (International Taxation), New Delhi

The appeal of the assessee stands allowed for statistical purposes

ITA 1087/DEL/2017[2011-12]Status: DisposedITAT Delhi04 Nov 2019AY 2011-12

Bench: Shri N.K. Billaiya & Shri Sudhanshu Srivastavasony Mobile Communications Vs. Dcit (International International Ab (India Branch Taxation) Office) Circle-3(1)(2) A-31, Mohan Cooperative New Delhi. Industrial Estate, Mathura Road, New Delhi – 110 044 Pan Aagcs4829J (Appellant) (Respondent) Asstt. Year: 2011-12

For Appellant: Shri Ajit Korde, AdvocateFor Respondent: Shri S.S. Rana, CIT (DR)
Section 139Section 139(4)

paid excess taxes. The AO was of the opinion that since the original return was filed belatedly, the assesee was not eligible to file revised return u/s 139 (5) of the Act. The assessee was asked to show cause as to why the revised computation of income should be considered ... held that the claim for expense/deduction and refund could not have been made before the AO except by filing a revised return and since the assessee had filed a belated return, the action of the AO in rejecting the assessee’s claim was fully justified. 2.4 Now the assessee

Tatva Gloabal Environment Ltd, Mumbai vs. ITO 9(3)(3), Mumbai

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

ITA 4012/MUM/2016[2011-12]Status: DisposedITAT Mumbai01 Nov 2019AY 2011-12

Bench: Shri Pawan Singh & Shri Rajesh Kumartatva Global Environment Ltd Vs Ito-9(3)(3), (Now Known As Tatva Global Aayakar Bhawan, M.K. Road, Environment Pvt Ltd) Mumbai Uniphos House, C D Marg, Opp Madhu Park, Khar (W) Mumbai 400 052 Pan : Aaics1718A Appellant Respondednt Dcit, Cent.Cir.6(3), Vs Tatva Global Environment Ltd Mumbai (Now Known As Tatva Global Environment Pvt Ltd) Uniphos House, C D Marg, Opp Madhu Park, Khar (W) Mumbai 400 052 Pan : Aaics1718A Appellant Respondednt

Section 10(34)Section 115OSection 14ASection 56(2)(viia)

assessee filed its return of income for assessment year (AY) 2011-12 on 30-09-2011 declaring Nil income. Subsequently, the assessee filed revised return of income on 30-10-2011 declaring loss of Rs.1.45 crores. The case was selected for scrutiny. During the assessment, the assessing officer (AO) noted

Income Tax Officer- 5(1), Indore vs. M/S. Su-Sampada, Indore

Appeal stands dismissed

ITA 504/IND/2018[2011-12]Status: DisposedITAT Indore31 Oct 2019AY 2011-12

Bench: Shri Kul Bharat & Shri Manish Borada.Y. 2011-12

Section 139(5)Section 80I

following grounds of appeal: “1. Whether on the facts and in circumstances of the case, ld. CIT(A) has erred in accepting the revised return filed on 10.9.2012 beyond the time allowed u/s 139(5) in which claim of deduction u/s 80IB(10) of Rs.3,94,16,079/- was made ... that the assessee filed return of income on 29.9.2011 declaring income at Rs.3,94,16,080/-. 4 Su-Sampada However, the assessee filed its revised return of income on 10.9.2012 showing nil income as it claimed deduction u/s 80IB(10) at Rs.3,94,16,079/-. The Assessing Officer asked

Citystar Ganguly Projects LLP, Kolkata vs. Principal CIT - 9, Kolkata

In the result, the appeal of the assessee is allowed

ITA 1103/KOL/2019[2014-15]Status: DisposedITAT Kolkata31 Oct 2019AY 2014-15

Bench: Shri J. Sudhakar Reddy, Am & Shri A. T. Varkey, Jm ]

Section 133(6)Section 143(3)Section 263

Amitabh Bachchan (supra) to impugn the order of the Tribunal. In the facts of the Supreme Court decision, the Respondent-Assessee had filed a revised return, claiming additional expenses. During the Assessment Proceedings, the Assessing Officer called upon the Assessee to furnish the details with regard to the expenses claimed ... balance available, seeking to invoke Section 69(C) of the Act and treat the expenditure claimed as unexplained expenditure, the Assessee therein withdrew his revised return of income. Once this was done, the Assessing Officer accepted the same and did not make any further enquiry. The CIT in exercise

Sandeep Bhimrao Lad, Mumbai vs. DCIT Circle-3, Thane

ITA 1620/MUM/2018[2009-10]Status: DisposedITAT Mumbai31 Oct 2019AY 2009-10

Bench: Shri S. Rifaur Rahman, Am & Shri Ram Lal Negi, Jm आयकरअपीलसं./ I.T.A. No. 1620/Mum/2018 (निर्धारणवर्ा / Assessment Year: 2009-10)

For Appellant: Shri Subodh RatnaparkhiFor Respondent: Shri V. Vinod Kumar, DR
Section 133(6)Section 148Section 271Section 274

reasons for such admission, (iv) CIT-Vs-Suresh Chandra Mittal 241 ITR 124 (MP) Assessee had declared additional income by way of revised returns after persistent queries by AO. Once the revised returns have been regularized by the revenue the explanation of the assessee that he has declared additional income ... surrendered the income after persistence queries by the 28 I.T.A. No. 1617 to 1620/Mum/2018 Sandeep Bhimrao Lad & Sunny Ashok Lad AO and where revised return has been regularized by the Revenue, explanation of the assessee that he has declared additional income to buy peach of mind and to come

Shri Nandkumar Babulal Soni, Mumbai vs. D.C.I.T. - Cent. Cir. 5(1), Mumbai

In the result, impugned order is confirmed and the appeal is dismissed

ITA 1061/MUM/2018[2014-15]Status: DisposedITAT Mumbai31 Oct 2019AY 2014-15

Bench: Shri Vikas Awasthy & Shri Rajesh Kumarshri Nandkumar Babulal Soni, 7/11, Chunawala Bldg., Kolsa Street, Pydhonie, Mumbai 400 003 Pan:Allps9573N ...... Appellant Vs. Dcit Cc-5(1), Air India Bldg., Nariman Point, Mumbai 400 021 ..... Respondent Appellant By : Shri Rajesh Sanghvi Respondent By : Ms. Kavita P. Kaushik Date Of Hearing : 18/09/2019 Date Of Pronouncement : 31 /10/2019

For Appellant: Shri Rajesh SanghviFor Respondent: Ms. Kavita P. Kaushik
Section 127Section 127(2)Section 132Section 153Section 153C

wrong person without any evidence and against the statements of various persons and the Angadia himself and even when the Aangadia filed a revised return withdrawing this claim in his revised return filed on 20-4-15. Presumably the only reason for assessing this income (by the Ahmedabad

M/S. Motorola Solutions India Pvt. Ltd., Gurgaon vs. DCIT, Gurgaon

Appeal of the assessee is partly allowed for statistical purpose

ITA 5797/DEL/2012[2008-09]Status: DisposedITAT Delhi31 Oct 2019AY 2008-09

Bench: Shri N.K. Billaiya & Ms Suchitra Kamble, [Assessment Year: 2008-09]

Section 143(3)Section 144CSection 92Section 92C

services. The assessee e-filed its Original Return declaring Income of Rs. 9,42,01,184/- on 30.09.2008. Thereafter, the Company e-filed its Revised Return of Income on 31.03.2010 declaring income of Rs. 9,42,01,184/-. A reference was made to the Transfer Pricing officer (TPO) to determine

DCIT, New Delhi vs. M/S Sahara India Prime City Ltd., Lucknow

In the result, appeal of the revenue is dismissed

ITA 3129/DEL/2011[2008-09]Status: DisposedITAT Delhi31 Oct 2019AY 2008-09

Bench: Shrig. S. Pannu,Hon’Ble & Shri K. N. Charydcit, Vs. M/S. Sahara India Prime City Ltd., Central Circle-6, 1, Kapoorthala Complex, Aliganj, New Delhi. Lucknow (Up) [Pan No.Aabcs 7893 P] (Appellant) .. (Respondent) Appellant By : Shri Sanjay Goel, Cit-Dr Respondentby : Shri Ajay Vohra, Sr. Advocate & Shri Durjan Mittal, C.A. Date Of Hearing 10.10.2019 Date Of Pronouncement 31.10.2019 O R D E R Per K. Narsimha Chary–:

For Appellant: Shri Sanjay Goel, CIT-DRFor Respondent: Shri Ajay Vohra, Sr. Advocate &
Section 14A

subsequent year a sum of Rs.34,90,243/- on account of expenses was found relatable to the year under assessment and, therefore, in the revised return of claim was made by the assessee. As per mercantile system of accounting, the expenditure was allowable in the year to which it relates

Sh. Krishan Kumar Goyal, Chandigarh vs. DCIT, CC-1, Chandigarh

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

ITA 456/CHANDI/2019[2007-08]Status: DisposedITAT Chandigarh30 Oct 2019AY 2007-08

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकर अपील सं./ Ita No. 226/Chd/2019 "नधा"रण वष" / Assessment Year : 2007-08 The Dcit, Shri Krishan Kumar Goyal, बनाम Central Circle-1, Prop Sagar Enterprise, Chandigarh Scf 153, Sector 26, Grain Market, Chandigarh "थायी लेखा सं./Pan No. Agipk9063H अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 456/Chd/2019 "नधा"रण वष" / Assessment Year : 2007-08 The Dcit, Shri Krishan Kumar Goyal, बनाम Central Circle-1, Prop Sagar Enterprise, Chandigarh Scf 153, Sector 26, Grain Market, Chandigarh "थायी लेखा सं./Pan No. Agipk9063H अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri Nikhil Goyal, AdvocateFor Respondent: Sh. Gulshan Raj, CIT DR
Section 139(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 68

153C cannot be interpreted to be further innings to the AO and/or assessee beyond the provisions of section 139(return of income), 139(5) (revised return of income), 147 (income escaping assessment) and 263(revision of orders) of the Act. The Hon’ble High Court has further observed that

Sh. Krishan Kumar Goyal, Chandigarh vs. DCIT, CC-1, Chandigarh

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

ITA 226/CHANDI/2019[2007-08]Status: DisposedITAT Chandigarh30 Oct 2019AY 2007-08

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकर अपील सं./ Ita No. 226/Chd/2019 "नधा"रण वष" / Assessment Year : 2007-08 The Dcit, Shri Krishan Kumar Goyal, बनाम Central Circle-1, Prop Sagar Enterprise, Chandigarh Scf 153, Sector 26, Grain Market, Chandigarh "थायी लेखा सं./Pan No. Agipk9063H अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 456/Chd/2019 "नधा"रण वष" / Assessment Year : 2007-08 The Dcit, Shri Krishan Kumar Goyal, बनाम Central Circle-1, Prop Sagar Enterprise, Chandigarh Scf 153, Sector 26, Grain Market, Chandigarh "थायी लेखा सं./Pan No. Agipk9063H अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri Nikhil Goyal, AdvocateFor Respondent: Sh. Gulshan Raj, CIT DR
Section 139(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 68

153C cannot be interpreted to be further innings to the AO and/or assessee beyond the provisions of section 139(return of income), 139(5) (revised return of income), 147 (income escaping assessment) and 263(revision of orders) of the Act. The Hon’ble High Court has further observed that