← All Phrases

“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

Chenthanmara Kp Nair, Mumbai vs. Dy. Commissioner of Income Tax - 42(2)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 4979/MUM/2025[2018-2019]Status: DisposedITAT Mumbai26 Sept 2025AY 2018-2019

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailchenthanmara Kp Nair, G-103 Ekta Bhoomi Garden 1 & H Co-Op. Hsg Soc. Ltd., Datta Pada Road, Borivali (East), Mumbai ............... Appellant Mumbai - 400066 V/S Deputy Commissioner Of Income Tax – 42(2)(1), C41-43, G Block Bkc, Gilban Area, ……………… Respondent Bandra Kurla Complex, Bandra East, Mumbai - 400051 Pan : Acrpn1974B Assessee By : Shri Uday P. Shah Revenue By : Shri Vikas Chandra, Sr.Dr

For Appellant: Shri Uday P. ShahFor Respondent: Shri Vikas Chandra, Sr.DR
Section 143(1)Section 205Section 250

that, in this regard, the assessee made all possible efforts to communicate with the deductor company for the payment of TDS and filing the revised return of TDS in order to claim the TDS credit. But the company has failed to pay the TDS to the Government. 6. We find

Puneet Khanna, Delhi vs. ITO Ward 3(1), Gurgaon

In the result, the appeal is allowed

ITA 3046/DEL/2025[2020-21]Status: DisposedITAT Delhi26 Sept 2025AY 2020-21

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Shri Puneet Khanna Vs. Income Tax Officer 8/51, Ramesh Nagar Ward-3(1) New Delhi Gurgaon Pan: Aajpk7067L Appellant Respondent Assessee By Sh. R. R. Gupta, Ca Revenue By Sh. Om Prakash, Sr. Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 26/09/2025 Order

Section 139(1)Section 143(1)Section 154Section 90

claimed FTC of Rs. 4,73,779/- u/s. 90 of the Act read with Article 24 of India Australia tax treaty ("DTAA") in a revised return of income filed on 31.8.2018. The Assessee had not filed the Form 67 before filing the return of income. On realising the same ... Assessee filed Form 67 in support of claim of foreign tax credit on 18.04.2020. The revised return of income was processed by Centralized Processing Centre (CPC) electronically and intimation u/s 143(1) of the Act on 28.05.2020 was passed disallowing the claim of FTC. 5. The Assessee filed a rectification

Mobineers Info Systems Pvt Ltd, New Delhi vs. Commissioner of Income Tax Appeals, CIT (A) NFAC Delhi

In the result, the Appeal of the Assessee is allowed

ITA 5564/DEL/2024[2020-21]Status: DisposedITAT Delhi26 Sept 2025AY 2020-21

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.Mobineers Info Systems Pvt. Vs Commissioner Of Income Ltd.O-44, Basement, Lajpat Tax (Appeals)/National Nagar-Ii, South Delhi-110065 Faceless Appeal Centre, Pan: Aaecm1120A Delhi Appellant Respondent Assessee By Sh. Piyush Kumar, Adv Revenue By Sh. Dheeraj Kumar Jain, Sr. Dr Date Of Hearing 02/08/2025 Date Of Pronouncement 26/09/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals/ National Faceless Appeal

Section 143Section 148Section 270ASection 270A(3)Section 274Section 44ASection 80J

income for Assessment Year 2020-21 declaring total taxable income of Rs. 35,47,800/- from business or profession. Subsequently the Assessee filed revised return declaring taxable income at Rs. 23,67,830/-. Initially, Assessee had claimed deduction u/s 80JJAA of the Income Tax Act, 1961 ('Act' for short) amounting

Oc Sweaters LLP, Mehrauli vs. Ward 29(5), New Delhi, Civic Centre

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

ITA 4363/DEL/2024[2018-2019]Status: DisposedITAT Delhi26 Sept 2025AY 2018-2019

Bench: the AO wherein the correct figures of new workmen were filled in. The AO had not accepted the said report as it was not filed online as provided in section 80JJAA of the Act and deduction claimed was disallowed.

Section 142Section 143(3)Section 250Section 8Section 80J

case of Jubilant Food Works Ltd. vs. ACIT (supra) allowed the deduction u/s 80JJAA where the report in Form 10DA was filed alongwith revised return and was not filed before the due date of furnishing of the original return. The Co-ordinate Bench held that non filing of the audit

O.C Sweater LLP, New Delhi vs. Income Tax Officer, New Delhi

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

ITA 3610/DEL/2024[2018-19]Status: DisposedITAT Delhi26 Sept 2025AY 2018-19

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 142Section 143(3)Section 250Section 8Section 80J

case of Jubilant Food Works Ltd. vs. ACIT (supra) allowed the deduction u/s 80JJAA where the report in Form 10DA was filed alongwith revised return and was not filed before the due date of furnishing of the original return. The Co-ordinate Bench held that non filing of the audit

Moraya Residency B Wing, Pune, Maharashtra vs. The ITO Ward 6(1), Pune, Maharashtra

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

ITA 1831/PUN/2025[2024-2025]Status: DisposedITAT Pune25 Sept 2025AY 2024-2025

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1831/Pun/2025 निर्धारण वषा / Assessment Year: 2024-25 Moraya Residency B Wing, V The Income Tax Officer, S.No.56/6, Opp. Samarth S Ward-6(1), Pune. Nagar, Near Mumbai Bengaluru Bypass, Vadgaon Budruk, Pune – 411041. Pan: Aaham9853D Appellant/ Assessee Respondent / Revenue Assessee By Shri C.H.Naniwadekar & Shri Kiran Sanmane – Ars Revenue By Shri Ambarnath Khule – Jcit(Dr) Date Of Hearing 02/09/2025 Date Of Pronouncement 25/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax Appeal(Nfac) Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2024-25 Dated 09.05.2025 Emanating From The Assessment Order Under Section 143(1) Of The Income Tax Act, 1961. The Grounds Of Appeal Raised By The Assessee Are As Under :

Section 115BSection 139(1)Section 143(1)Section 250Section 80PSection 80P(2)(d)

case that the assessee has filed Form 10-IE and also filed the return under the new tax regime and thereafter filed a revised return withdrawing the option which according to us is not permissible in the said previous year and the assessee can change the option only

Mohan Roshan, Bengaluru vs. Income Tax Officer, Ward-7(2)(5), Bangalore

In the result, appeal filed by theassessee is dismissed

ITA 1390/BANG/2025[2018-19]Status: DisposedITAT Bangalore25 Sept 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahuassessment Year : 2018-19 Shri. Roshan Mohan, Vs. Ito, M-30C, Forest Quarters, 18Th Main, Ward – 7(2)(5), Malleshwaram, Bangalore. Bangalore – 560 055. Pan : Ajqpr 4955 Q Appellant Respondent Assessee By : Shri. Deepak Chopra, Ca Revenue By : Shri. Ganesh R. Ghale, Advocate, Standing Counsel For Revenue. Date Of Hearing : 10.09.2025 Date Of Pronouncement : 25.09.2025

For Appellant: Shri. Deepak Chopra, CAFor Respondent: Shri. Ganesh R. Ghale, Advocate, Standing Counsel for Revenue
Section 194JSection 44A

appeal : Page 2 of 10 2. from the above grounds it is clear that sole issue raised by the assessee is regarding not accepting revised return filed by the assessee. 3. Briefly stated, the facts of the case are that assessee filed his return of income on 08.08.2018 declaring total ... income of Rs.16,44,968/- for Assessment Year 2018-19 and has revised return of income on 29.03.2019 declaring total income of Rs.2,47,000/-. The case was selected for scrutiny to examine the issue of reduction of income in revised income as compared to original return of income. Accordingly

DCIT Central Circle 3(2), Mumbai, Air India vs. Aarti Industries Limited, Mumbai

In the result, the appeal is dismissed

ITA 4869/MUM/2023[2015-2016]Status: DisposedITAT Mumbai25 Sept 2025AY 2015-2016

Bench: Shri Saktijit Dey & Shri Girish Agrawaldy. Cit, Central Circle-3(2) Aarti Industries Limited R. No. 1913, 19Th Floor, 71, Udyog Kshetra, 2Nd Floor, Air India Building, Nariman Point, Vs. Mulund Goregaon Link Road, Mumbai-400 021 Mulund (W), Mumbai-400 080 Pan/Gir No. Aabca 2787 L (Appellant) : (Respondent) Appellant By : Shri Vijay Mehta Respondent By : Shri Rajesh Kumar Yadav Date Of Hearing : 12.08.2025 Date Of Pronouncement : 25.09.2025 O R D E R Per Saktijit Dey: This Is An Appeal By The Revenue, Against The Order Dated 30.10.2023 Of Learned Commissioner Of Income Tax (Appeals), Mumbai (‘Ld.Cit(A) For Short), Pertaining To The Assessment Year (A.Y.) 2015-16. 2. Ground No. 1 In The Appeal Reads As Under: 1. On The Facts & Circumstances Of The Case, The Ld. Cit(A) Erred In Deleting The Disallowances Made By The A.O. To Restrict The Deduction U/S. 80Ia Of The Act Despite The Fact That The Issue Has Not Attained Finality & Pending For Adjudication Before The Hon'Ble Supreme Court? – Rs.396,81,798/- 3. Briefly The Facts Are, The Assessee Is A Resident Corporate Entity Engaged In Manufacturing & Sale Of Chemicals, Fertilizers & Intermediaries. For Such Manufacturing Activity, The Assessee Has Set Up A Plant At Plot No. 801/23, Gidc, Phase-Iii

For Appellant: Shri Vijay MehtaFor Respondent: Shri Rajesh Kumar Yadav
Section 133(6)Section 80I

Goetze (India) Limited vs. CIT [2006] 157 Taxman 1 (SC), the A.O. declined to entertain the claim as it was not made through a revised return of income. 29. Against the aforesaid decision, the assessee approached ld. first appellate authority. While deciding the issue, ld. first appellate authority not only ... Before us, ld. Departmental Representative (ld. DR for short) submitted that firstly, the fresh claim made by the assessee without filing any revised return of income could not have been accepted by the A.O., hence, he was justified in disallowing assessee’s claim. Without prejudiced, he submitted that the nature

Manpowergroup Services India Private Limited, Delhi vs. Assistant Commissioner of Income Tax, Central Circle 2, Delhi, Jhandewalan Extension, New Delhi

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

ITA 3585/DEL/2024[2020-2021]Status: DisposedITAT Delhi25 Sept 2025AY 2020-2021

Bench: Shri Mahavir Singh & Shri Naveen Chandra

For Appellant: Shri S.K. Agarwal, ARFor Respondent: Shri Dharm Veer Singh, CIT-DR
Section 143(3)Section 80JSection 92CSection 92D

meet other client needs. 6. The assessee filed its return u/s 139(1) on 15.02.2021 declaring nil income. The assessee filed a revised return on 31.03.2021 declaring nil income. In the assessment year 2020-21, the assessee in the return of income claimed following deduction u/s 80JJAA, being

Om Sree Siva Shankar Educational Society, Visakhapatnam vs. Income Tax Officer, Ward-1(1), Visakhapatnam

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

ITA 279/VIZ/2025[23017-18]Status: DisposedITAT Visakhapatnam24 Sept 2025

Bench: The Ld. Addl/Jcit(A)-1, Lucknow.

Section 10Section 119(2)Section 143(1)

assessee and dismissed the assessee’s appeal by observing as under: “8.2. ….it is important to note that the appellant has not filed a revised return to rectify the mistakes made in the original return. Under the Income Tax Act, claimed or submissions not included in the original return cannot ... accepted unless a revised return is filed. This principle is in line with the decision of the Hon’ble Supreme Court in Goetz (India) Ltd vs. CIT (2006) 284 ITR 323 (SC) which established that modifications or claim not made in the original return must be addressed through the filing

Paladugu Reshma, Vijayawada vs. Income Tax Officer, Ward-2(3), Vijayawada

In the result, appeal of the assessee is partly allowed

ITA 268/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam24 Sept 2025AY 2017-18

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.268/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2017-18) Paladugu Reshma V. Income Tax Officer – Ward – 2(3) D.No. 57-7-11 Income Tax Office New Postal Colony Cr Building, 1St Floor, Annex Kakatiya Clinic Road M.G.Road, Vijayawada Patamata, Vijayawada - 520010 Andhra Pradesh [Pan: Amupp5831A] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 142(1)Section 143(2)Section 143(3)Section 69A

Income Tax Act, 1961 (in short ‘Act’) dated 25.11.2019. 2. Brief facts of the case are that, assessee is an individual and filed her revised return of income for the A.Y.2017-18 on 03.08.2017 admitting a total income of Rs.3,56,360/-. Subsequently, the case was selected for limited scrutiny

Shree Shantanu Vidhyapeeth Society, Indore, M.P vs. The Income Tax Officer, NFAC, Delhi

Appeal is allowed for statistical purpose

ITA 640/IND/2024[2018-19]Status: DisposedITAT Indore24 Sept 2025AY 2018-19

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi**

Section 10Section 11Section 12ASection 12A(2)Section 139Section 142(1)Section 143(3)

filling Form 10B and also relied on CBDT circular and case laws.* *6.1 In this regards, it is submitted that the assessee has not revised return of income for A.Y. 2018-19, it is pertinent to mention here that power of condonation of delay u/s 119(2)(b) does ... been assigned by AO and the last reason has been added by CIT(A). These three reasons are: - (i) The assessee has not filed revised return claiming exemption u/s 11/12. Ld. AR pointed out that although the AO has not specifically mentioned but this adverse observation may be in tune

Whole Sale Cloth Merchant Association, Kota vs. Deputy Commissioner of Income Tax Central Circle Kota, Kota

ITA 962/JPR/2024[2015-2016]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-2016
For Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 11Section 11(2)Section 143(3)Section 147Section 40

Since, the assessee neither made any such claim in the original retum filed under Section 139(1) of the Act nor in revised return therefore returns filed in response to notice under Section 148 of the Act are not substitute of revised return for making claim of such benefits. Having

Assistant Commissioner of Income Ta, Jaipur vs. Shri Nath Corporation, Jaipur

In the result, the appeals filed by the Revenue are dismissed

ITA 267/JPR/2024[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16
For Appellant: Shri Hemang Gargieya, Adv. &
Section 133ASection 271(1)(c)

Court in this case as under:- "20. Therefore, the position that emerges from the above-mentioned provision is that once the assessee files a revised return under Section 153A, for all other provisions of the Act, the revised return will be treated as the original return filed under Section ... income assessed over and above the income returned under s.153A, if any." 21. Thus, it is clear that when the A.O. has accepted the revised return filed by the assessee wonder Section 153A, no occasion arises to refer to the previous return filed sunder Section

Assistant Commissioner of Income Tax, Jaipur vs. Jitendra Kumar Agarwal, Jaipur

In the result, the appeals filed by the Revenue are dismissed

ITA 197/JPR/2024[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Hemang Gargieya, Adv. &For Respondent: Shri Ajey Malik, CIT (through V.C.) a
Section 133ASection 271(1)(c)

Court in this case as under:- "20. Therefore, the position that emerges from the above-mentioned provision is that once the assessee files a revised return under Section 153A, for all other provisions of the Act, the revised return will be treated as the original return filed under Section ... 197/JPR/2024 14 Shri Nath Corporation & Ors., Jaipur. 21. Thus, it is clear that when the A.O. has accepted the revised return filed by the assessee wonder Section 153A, no occasion arises to refer to the previous return filed sunder Section 139 of the Act. For all purposes, including

Assistant Commissioner of Income-Tax, Jaipur vs. Royal Jewellers, Jaipur

In the result, the appeals filed by the Revenue are dismissed

ITA 196/JPR/2024[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16
For Appellant: Shri Hemang Gargieya, Adv. &
Section 133ASection 271(1)(c)

Court in this case as under:- "20. Therefore, the position that emerges from the above-mentioned provision is that once the assessee files a revised return under Section 153A, for all other provisions of the Act, the revised return will be treated as the original return filed under Section ... income assessed over and above the income returned under s.153A, if any." 21. Thus, it is clear that when the A.O. has accepted the revised return filed by the assessee wonder Section 153A, no occasion arises to refer to the previous return filed sunder Section

Vibha Agrotech Ltd., Hyd, Hyderabad vs. DCIT, Circle-3(3), Hyderabad

In the result appeal of the Revenue and appeal of the Assessee are dismissed

ITA 331/HYD/2016[2011-12]Status: DisposedITAT Hyderabad24 Sept 2025AY 2011-12

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: -None-For Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 10(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 14ASection 35

ITA.Nos.289 & 331/Hyd./2016 2. The Ld. CIT (A) erred in not allowing the Income admitted by the assessee in the Revised Return of Income as cultivation income. 2.a The Ld. CIT(A) erred in denying the exemption u/s 10(1) of the Act for which the assessee ... were issued. In response to notice under section 142(1) dated 14.03.2014, the assessee has enclosed copy of revised return filed on 19.02.2014 declaring total 5 ITA.Nos.289 & 331/Hyd./2016 income at Rs.NIL. The Assessing Officer rejected the revised return filed by the assessee on the ground that, the said

DCIT, Circle-17(2), Hyd, Hyderabad vs. Vibha Agrotech Ltd., Hyd, Hyderabad

In the result appeal of the Revenue and appeal of the Assessee are dismissed

ITA 289/HYD/2016[2011-12]Status: DisposedITAT Hyderabad24 Sept 2025AY 2011-12

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: -None-For Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 10(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 14ASection 35

ITA.Nos.289 & 331/Hyd./2016 2. The Ld. CIT (A) erred in not allowing the Income admitted by the assessee in the Revised Return of Income as cultivation income. 2.a The Ld. CIT(A) erred in denying the exemption u/s 10(1) of the Act for which the assessee ... were issued. In response to notice under section 142(1) dated 14.03.2014, the assessee has enclosed copy of revised return filed on 19.02.2014 declaring total 5 ITA.Nos.289 & 331/Hyd./2016 income at Rs.NIL. The Assessing Officer rejected the revised return filed by the assessee on the ground that, the said

Dy.C.I.T., CC-4(4), Mumbai vs. Capsave Finance Pvt. Ltd., Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 3872/MUM/2025[2018-19]Status: DisposedITAT Mumbai24 Sept 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

For Appellant: Shri Niraj D SethFor Respondent: Mr. Virabhadra S. Mahajan (Sr
Section 139(5)

which establishes that the Assessing Officer has no power to entertain a claim of deduction otherwise than through a revised return.” 3. The brief factual background may be recounted. The assessee, a Non-Banking Financial Company engaged in the business of leasing and asset financing, filed its return of income ... declaring nil income, followed by a revised return on 28.03.2019, again declaring nil income. In its books, the assessee has consistently followed generally accepted accounting principles and Accounting Standards, offering rental income and claiming depreciation on operating leases, but in the P a g e | 3 CAPSAVE FINANCE

Keezhuparamba Service Cooperative Bank Ltd, Malappuram vs. ITO Ward 2, Tirur

Appeal is treated as allowed for statistical purposes

ITA 568/COCH/2025[2022-23]Status: DisposedITAT Cochin22 Sept 2025AY 2022-23

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Raghunathan PFor Respondent: Shri Sanjit Kumar Das
Section 143(3)Section 2Section 250Section 80P

accepted:” 4. The relevant facts in brief are that the Assessee, a co-operative society registered under Kerala Co-Operative Societies Act, filed a revised return of income on 29/12/2022 for the Assessment Year 2022-2023 declaring ‘Nil’ income after claiming deduction under Section 80P of the Act in respect