“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

Dy. Commissioner of Income Tax, Circle-1, Thane, Wagle Industrial Estate, Thane West vs. M M Plastoware India Private Limited, Thane

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

ITA 133/MUM/2025[2016-17]Status: DisposedITAT Mumbai10 Mar 2026AY 2016-17

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2016-17 Deputy Commissioner Of M M Plastoware India Private Income Tax, Circle-1, Thane Limited Gala No. 10-15, Arihant Darshan, Vs. 90 Feet Road, Bhayander West, Thane – 101101. (Pan: Aahcm2568D) (Appellant) (Respondent) C.O. No. 120/Mum/2025 Assessment Year: 2016-17 M M Plastoware India Private Deputy Commissioner Of Income Limited Tax, Circle-1, Thane Gala No. 10-15, Arihant Darshan, 90 Feet Road, Vs. Bhayander West, Thane – 101101. (Pan: Aahcm2568D) (Appellant) (Respondent) Present For: Assessee : Shri Lalit Munoyat, Ca Revenue : Shri Bhagirath Ramawat, Sr. Dr Date Of Hearing : 22.12.2025 Date Of Pronouncement : 10.03.2026 O R D E R Per Girish Agrawal:

For Appellant: Shri Lalit Munoyat, CAFor Respondent: Shri Bhagirath Ramawat, Sr. DR

Section 143(3)Section 254Section 32(1)(ila)

Income-tax Act, 1961, solely on the ground that such claim was not made in the original return of income and that no revised return had been filed, and whether the learned CIT(A) rightly granted relief on this issue? 2. Whether the rejection of the Cross Objector's claim ... wherein it was held whether an assessee can make an additional claim of deduction through a letter during assessment proceedings without filing a revised return, and whether the appellate authorities have jurisdiction to entertain such claims and other decisions, which categorically hold that correction of errors or recomputation of existing

Aarti Gupta, Chandigarh vs. ITO, Ward 1, Panchkula

The appeal stand allowed

ITA 1612/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh09 Mar 2026AY 2019-20

Bench: SHRI LALIET KUMAR (Judicial Member), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Sh. T.N. Singla (CA) – Ld. ARFor Respondent: Sh. Vivek Vardhan (Addl. CIT) – Ld. Sr. DR

Section 143(1)Section 154

return u/s 143(1) on 24-01-2020. The assessee filed rectification on 17-02-2020 which is still pending. The assessee had filed revised return of income which was processed u/s 143(1) on 16-04-2020 against which another rectification was filed by the assessee

Meridian Marketers, Hyderabad vs. ACIT, Central Circle-2(1), Hyderabad

In the result, appeal of the Assessee is dismissed

ITA 1879/HYD/2025[2022-23]Status: HeardITAT Hyderabad06 Mar 2026AY 2022-23

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.1879/Hyd/2025 Assessment Year 2022-2023 Meridian Marketers, The Acit, Hyderabad. Telangana. Central Circle-2(1), Vs. Pin 500 033. Hyderabad. Pan Abmfm1321M Telangana. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By -None- राज" व "ारा/Revenue By : Sri Mathivanan S A, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 03.03.2026 घोषणा की तारीख/Pronouncement: 06.03.2026 आदेश/Order Per Vijay Pal Rao:

For Respondent: Sri Mathivanan S A, Sr. AR

Section 131Section 132ASection 139(4)Section 139(5)Section 148Section 148ASection 250Section 69A

income u/sec.139(4) of the Income Tax Act [in short "the Act"], 1961 on 27.12.2022 declaring total income of Rs.56,41,390/-. A revised return u/sec.139(5) of the Act was also filed admitting the same income. There were a search and seizure by the Railway Protection Force [in short

Amith Vishnav Gudimella, Hyderabad vs. ITO, Ward-12(1), Hyderabad

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

ITA 1705/HYD/2025[2020-21]Status: HeardITAT Hyderabad06 Mar 2026AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.1705/Hyd/2025 Assessment Year 2020-2021 Amith Vishnav The Income Tax Officer, Gudimella, Hyderabad. Ward-12(1), Pin – 500 008. Telangana. Vs. Hyderabad. Pan Aghpv2565J Telangana. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By Sri T Chaitanya Kumar, Advocate राज" व "ारा/Revenue By : Ms Reema Yadav, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 03.03.2026 घोषणा की तारीख/Pronouncement: 06.03.2026 आदेश/Order Per Vijay Pal Rao:

For Respondent: MS Reema Yadav, Sr. AR

Section 143(1)Section 154Section 90Section 91

relevant material available on record. There is no dispute that the assessee has declared the salary income earned in US in the revised return of income filed on 23/02/2021 and also claimed FTC by filing Form-67 along with the revised return. Thus, before the revised return, the assessee ... neither declared the salary income earned in the US, nor claimed FTC. When the revised return of the assessee was filed within the limitation provided under section 139(5) of the Act, then the claim of FTC of the assessee is linked with the foreign income declared in the revised

Valuelabs LLP, Hyderabad vs. DCIT., Central Circle 8(1), Hyderabad

ITA 1609/HYD/2025[2020-21]Status: DisposedITAT Hyderabad06 Mar 2026AY 2020-21

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी. सं/Ita No.1609/Hyd/2025 (निर्धारण वर्ष/Assessment Year:2020-21) Valuelabs Llp, Hyderabad. Vs. Dcit, Pan: Aakfv2276K Central Circle-8(1), Hyderabad. (Appellant) (Respondent) निर्धारिती द्वारा/Assessee By: Shri P. Murali Mohan, Ca राजस्व द्वारा / Revenue By: Ms. U. Mini Chandran, Cit-Dr सुनवाई की तारीख / Date Of Hearing: 29/01/2026 घोषणा की तारीख / Date Of 06/03/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Firm Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 13/08/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 143(3) R.W.S 144B Of The Income Tax Act, 1961 (For Short, "The Act"), Dated 27/09/2022 For The Assessment Year (Ay) 23/11/2021. The Assessee Firm Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri P. Murali Mohan, CAFor Respondent: Ms. U. Mini Chandran

Section 115BSection 143(3)Section 2(24)(xviii)Section 250Section 80

ought to have appreciated the fact that assessee is eligible for exemption/ deduction even if the same is not claimed in the original or revised return. 16. Appellant may, add or alter or amend or modify or substitute or delete and/or rescind all or any of the grounds of appeal

Shri Gaurav Agarwal, Darjeeling vs. ITO, Ward 1(3), Siliguri

In the result, the appeal of the assessee is allowed

ITA 1887/KOL/2025[2015-2016]Status: DisposedITAT Kolkata06 Mar 2026AY 2015-2016

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 147Section 148Section 148ASection 250oSection 69A

consequent assessment framed by the AO. 3. The facts in brief are that the assessee filed revised return of income on 16.05.2022 declaring income at Rs. 5,27,690/-. Thereafter, the AO on 2 Shri Gaurav Agarwal the basis of insight portal information noted that there were substantial credits

Portescap India Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 2(3)(1), Mumbai

In the result, the appeal filed by the assessee is allowed in light of aforesaid directions

ITA 7479/MUM/2025[2019-20]Status: DisposedITAT Mumbai05 Mar 2026AY 2019-20

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhailassessment Year : 2019-20 Portescap India Private Limited, The Deputy Commissioner Of Unit No. 101, Tower Ii, Income Tax, Seepz Sez, Vs. Circle-2(3)(1), Andheri East, Room No. 552, 5Th Floor, Seepz S.O., Aayakar Bhavan, Mumbai-400096. M.K.Road, Pan : Aaack4896K Mumbai-400020. (Appellant) (Respondent) For Assessee : Shri Pranay Gandhi A/W. Shri Lekh Mehta, For Revenue : Shri R.A. Dhyani, Cit-Dr Date Of Hearing : 17-02-2026 Date Of Pronouncement : 05-03-2026 O R D E R Per Vikram Singh Yadav, A.M :

For Appellant: Shri Pranay Gandhi a/wFor Respondent: Shri R.A. Dhyani, CIT-DR

Section 10ASection 143(1)Section 143(1)(a)Section 154Section 234BSection 250Section 43B

from perusal of records, it is evident that the 5 assessee has filed its original return of income on 30-11-2019 and revised return of income on 15-07-2020. In the return of income so filed, the assessee has claimed deduction u/s 10AA amounting

Deputy Commissioner of Income Tax, Central Circle 6(2), Mumbai vs. Tata Aig General Insurance Co. Ltd, Mumbai

In the result the appeal of the revenue’s bearing ITA No

ITA 2398/MUM/2024[2020-21]Status: DisposedITAT Mumbai05 Mar 2026AY 2020-21

Bench: Shri Anikesh Banerjee & Shri Jagadish

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Ritesh Misra (CIT DR)

Section 10(38)Section 111ASection 112Section 139(1)Section 143(3)Section 234ASection 234BSection 234DSection 250

profits and gains of business profession" instead of income under the head "capital gains", as per the position adopted by the assessee in its revised return of income. TATA AIG General Insurance Company Ltd. 44.1. In respect of this claim, reason for revision is based on CBDT circular No. 06/2016 ... income as business income. It is only in this assessment year that it has been characterised as capital gain by way of filing of revised return under section 139(5) of the Act. Thus, the aforesaid CBDT circular has given a concession to the assessee which cannot be denied since

Tata Aig General Insurance Company Limited, Mumbai vs. Assistant Commissioner of Income-Tax-8(3)(1), Mumbai

In the result the appeal of the revenue’s bearing ITA No

ITA 1450/MUM/2024[2018-19]Status: DisposedITAT Mumbai05 Mar 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Jagadish

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Ritesh Misra (CIT DR)

Section 10(38)Section 111ASection 112Section 139(1)Section 143(3)Section 234ASection 234BSection 234DSection 250

Tulsidas Virji Chothani, Mumbai vs. Income-Tax Officer Ward 27(3)(1), Mumbai

In the result, the appeal by the assessee is allowed

ITA 319/MUM/2026[2016-17]Status: DisposedITAT Mumbai04 Mar 2026AY 2016-17

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailtulsidas Virji Chothani, 601, 6Th Floor, Shantrunjay Building, Neelkanth Valley, Ghatkopar East, Mumbai - 400077 ............... Appellant Pan: Aabpc0337M V/S Income Tax Officer, Ward-27(3)(1) It-Office, Vasi Railway Station Building, ……………… Respondent Navi Mumbai - 400703

For Appellant: Shri Mehul ShahFor Respondent: Shri Pravin Salunkhe, Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 250Section 44A

held that even if the assessee had wrongly shown its turnover in the original return of income, it was required to file the revised return of income within the provisions of the Act. Thus, it was held that a mere claim for correct turnover is not maintainable without filing ... valid revised return of income, which the assessee has failed to do. Accordingly, the AO made an addition of Rs. 27,88,435. 6. The learned CIT(A), vide impugned order, dismissed the appeal filed by the assessee on this issue, by observing as follows: – 4 “4.1.2 Ground of appeal

Ramesh Nanji Gami, Navi Mumbai vs. Assistant Commissioner of Income Tax, Navi Mumbai

In the result, appeal of the assessee is allowed

ITA 6027/MUM/2025[2017-2018]Status: DisposedITAT Mumbai04 Mar 2026AY 2017-2018

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

Section 143(3)Section 250Section 36Section 36(1)Section 57

business and profession and not under head income from other sources. Appellant contends that NFAC and Ld.AO both have failed to appreciate that once revised return is filed by Appellant, the provision of section 57 cannot be involved. The Appellant craves leaves to alter, amend, withdraw OR substitute any ground

St. Josephs Education Trust Vijapur, Mehsana vs. The ITO, Exemption Ward, Palanpur

In the result, the appeal filed by the Assessee is treated as allowed for statistical purpose

ITA 445/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad03 Mar 2026AY 2019-20

Bench: Ld. Cit(A).

Section 10Section 11Section 143(1)Section 154

already filed on 25.10.2019 The same being within the custody of the Income tax Department and such omission was later corrected by filing Revised return, the intimation making entire disallowance of amount applied/ expended as per Audited accounts and as per very same Return which is processed 4. Without prejudice

DCIT-4(1), Indore vs. Maral Overseas Ltd, Khargone

In the result, the “Impugned

ITA 569/IND/2025[1992-93]Status: DisposedITAT Indore27 Feb 2026AY 1992-93

Bench: Shri B.M. Biyani & Shri Paresh M Joshideputy Commissioner Of Maral Overseas Ltd. बनाम/ Income Tax- 4(1) Maral Srovar, V & Po, Vs. Indore Khalbujurg, Kasrawad, Khargone, Bhopal (Pan: Aaccm0230B) (Appellant) (Respondent) Assessee By Shri Satyajeet Goyal, Ca Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 03.02.2026 Date Of Pronouncement 27.02.2026

Section 143(3)Section 250Section 253

other sources and adjusted the capitalisation of pre-operative expenses for the purposes of claiming depreciation for the income tax return. b. In the revised return filed on 16.07.1993, the company though offered the said interest as income from other sources, however, it was claimed by way of a note ... assessee has disclosed income of interest on share application money of Rs. 1,51,54,534/- as the income of the year in the revised return. Since Page 5 of 56 Maral Overseas Ltd. ITA No. 569/Ind/2025 - A.Y.1992-93 the claim made by the assessee company through a note appended

B.V.Kapadia HUF, Kolkata vs. D.C.I.T, CPC, Bengaluru

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

ITA 2879/KOL/2025[201-22]Status: DisposedITAT Kolkata27 Feb 2026

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 139Section 139(5)Section 143(1)Section 199Section 250

that dividend income had been duly offered to tax by the appellant. 3. The learned CIT(A) grossly erred in holding that filing a revised return u/s 139(5) was the only remedy, ignoring the settled principle that where income ITA No.: 2879/KOL/2025 Assessment Year: 2021-22 B.V. Kapadia ... 2879/KOL/2025 Assessment Year: 2021-22 B.V. Kapadia HUF. wrong statement was noticed in the return of income, the appellant was required to file a revised return under section 139(5) of the Income-tax Act within the prescribed time-limit. 6.2 Further, it is pertinent to mentioned here that

M/S Vardhman Textiles Ltd vs. C I T and Anr

ITA/517/2008HC Punjab & Haryana26 Feb 2026

Bench: MR. JUSTICE AMARINDER SINGH GREWAL,MR. JUSTICE JAGMOHAN BANSAL

Section 10Section 143(1)Section 260ASection 80Section 80l

Rs.28.04 crore. The return was processed under Section 143(1) of 1961 Act and refund of Rs.2.92 crore was assessed. The appellant filed revised return on 18.07.2001 revising its total income from Rs.28.04 crore to 26.73 crore. The Assessing Officer vide order dated 31.03.2003 assessed appellant’s income

Alpa Harshadbhai Gandhi, Ahmedabad vs. The ITO, Ward-5(3)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 2153/AHD/2025[2023-24]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2023-24

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2023-24

For Appellant: Shri D K Parikh, A.RFor Respondent: Shri Veerbadram Vislavath, Sr. D.R

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

filed her income on 11-09-2023 which is well within the due date of filing of return i.e. 31-10-2023 and the revised return was also filed on 21-10-2023 prior to the said due date i.e. 31-10-2023. Form 10IE was also filed

Savitaben Navinbhai Patel, Unjha vs. Income Tax Officer, Ward-1, Patan

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

ITA 1881/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2013-14

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2013-14

For Appellant: Shri K.C. Thaker, A.RFor Respondent: Shri Veerbadram Vislavath, Sr. D.R

Section 148Section 69A

case was selected for scrutiny and the assessee was issued notice u/s. 148 of the Act on 31-03-2020. The assessee filed revised return of income on 16-06-2020. The Assessing Officer held that the assessee declared very low income which cannot justify her eligibility to take loan

Hemaben Babubhai Parekh, Mumbai vs. DCIT 19(1), Mumbai

ITA 8549/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Feb 2026AY 2019-20

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Ms. Sneha KothariFor Respondent: Shri Bhagirath Ramawat

Section 139(1)Section 144BSection 147Section 148Section 80G

notice issued under Section 148 of the Act. 7. On comparing the computation of income filed with the original return of income and revised return of income, we find that as per the original as well as the revised computation of income, the Assessee had offered to tax INR.7 ... Section 80GGC of the Act and had offered to tax additional income of INR.200,000/- under the head ‘Income from Other Sources’ in the revised return. 3 Assessment Year 2019-2020 9. The case of the Assessee is that by doing as above, the Assessee had offered to tax additional

Bobst Bielefeld Gmbh, Germany vs. The Assistant Commissioner of Income Tax Int Tax Circle 1(3)(1), Mumbai

ITA 6030/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Feb 2026AY 2018-19

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Siddesh ChauguleFor Respondent: Shri Krishna Kumar, Sr.DR

Section 234Section 234ASection 270A

relief claim. The claim of the appellant is that its own ITR should be allowed to be modified without resorting to filing of a revised Return or filing a revised Return u/s.119(2)(b) of the Act and it has been further claimed that the onus lies

Bobst Bielefeld Gmbh, Germany vs. The Assistant Commissioner of Income Tax Int Tax Circle 1(3)(1), Mumbai

ITA 6029/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Siddesh ChauguleFor Respondent: Shri Krishna Kumar, Sr.DR

Section 234Section 234ASection 270A