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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

M/S. Thyssenkrupp Elevator (India) Pvt. Ltd., New Delhi vs. DCIT, New Delhi

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

ITA 987/DEL/2014[2008-09]Status: DisposedITAT Delhi14 Sept 2018AY 2008-09

Bench: Shri G.D. Agrawal & Shri Amit Shukla

For Appellant: Shri S.D. Kapila, Adv. & Shri R.RFor Respondent: Shri Amit Jain, Sr.D.R
Section 143(3)Section 154

erred in admitting additional ground of appeal which the assessee had neither raised at the stage of scrutiny proceedings nor in its revised return and directing the Assessing Officer to verify the claim of the appellant from its record and allow depreciation on the goodwill.” 22. Thus, the only ground ... erred in admitting the additional ground of appeal which was not raised during the course of the assessment proceedings nor in the revised return. Here, in this case, the assessee has filed an application u/s.154 on the ground in the first appeal filed before the ld. CIT(A) the assessee

DCIT, New Delhi vs. M/S. Thyssenkrupp Elevator (India) Pvt. Ltd., New Delhi

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

ITA 871/DEL/2014[2008-09]Status: DisposedITAT Delhi14 Sept 2018AY 2008-09

Bench: Shri G.D. Agrawal & Shri Amit Shukla

For Appellant: Shri S.D. Kapila, Adv. & Shri R.RFor Respondent: Shri Amit Jain, Sr.D.R
Section 143(3)Section 154

erred in admitting additional ground of appeal which the assessee had neither raised at the stage of scrutiny proceedings nor in its revised return and directing the Assessing Officer to verify the claim of the appellant from its record and allow depreciation on the goodwill.” 22. Thus, the only ground ... erred in admitting the additional ground of appeal which was not raised during the course of the assessment proceedings nor in the revised return. Here, in this case, the assessee has filed an application u/s.154 on the ground in the first appeal filed before the ld. CIT(A) the assessee

DCIT, New Delhi vs. M/S. Thyssenkrupp Elevator (I) P. Ltd., New Delhi

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

ITA 4708/DEL/2014[2008-09]Status: DisposedITAT Delhi14 Sept 2018AY 2008-09

Bench: Shri G.D. Agrawal & Shri Amit Shukla

For Appellant: Shri S.D. Kapila, Adv. & Shri R.RFor Respondent: Shri Amit Jain, Sr.D.R
Section 143(3)Section 154

erred in admitting additional ground of appeal which the assessee had neither raised at the stage of scrutiny proceedings nor in its revised return and directing the Assessing Officer to verify the claim of the appellant from its record and allow depreciation on the goodwill.” 22. Thus, the only ground ... erred in admitting the additional ground of appeal which was not raised during the course of the assessment proceedings nor in the revised return. Here, in this case, the assessee has filed an application u/s.154 on the ground in the first appeal filed before the ld. CIT(A) the assessee

M/S. Indian Roadways Corporation Ltd., Kolkata vs. Principal CIT, Central - 1, Kolkata

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

ITA 787/KOL/2018[2009-10]Status: DisposedITAT Kolkata12 Sept 2018AY 2009-10

Bench: Shri A.T.Varkey, Jm & Dr. A.L. Saini, Am Vs. Principal Commissioner Of M/S Indian Roadways Corporation Ltd. Income Tax, Central-I, Irc House, 1, Sunyat Sen Street, Kolkata, Aayakar Bhawan Kolkata-700012. Poorva, 110, Shantipally, Kolkata-700107. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaaci 7333 K (अपीलाथ" /Appellant) (""यथ" / Respondent) ..

For Appellant: Shri S.K.Tulsiyan, AdvocateFor Respondent: Shri P.K.Srihari, CIT(DR)
Section 132Section 143(3)Section 153ASection 154Section 263Section 36

income for the assessment year 2009-10 on 30.05.2015, declaring a total income to the tune of Rs.36,23,652/-, as shown in the revised return of income filed by the assessee subsequent to original return of income. Assessment under section 153A/143(3) was completed on 31.03.2016 assessing the total ... seizure operation, assessee company filed its return of income on 30/05/2015 declaring the total income of Rs.36,23,652/- as shown in the revised return filed subsequent to original return of income. Assessment u/s.143(3)/153A was completed on 31/03/2016 by the AO assessing the total income at Rs.52

M/S. Pricewaterhousecoopers Private Limited, Kolkata vs. ACIT, Cir-2(2), Kolkata

ITA 483/KOL/2017[2012-13]Status: DisposedITAT Kolkata12 Sept 2018AY 2012-13

Bench: Shri S.S.Godara & Shri, M. Balaganeshassessment Year :2012-13 M/S Pricewaterhousecoopers V/S. Acit, Circle-2(2), Pvt.Ltd., Block-Ep, Plot-Y-14, Aayakar Bhavan, P-7, Salt Lake City, Sector-V, Chowringhee Square, Kokata-91 Kokata-69 [Pan No.Aabcp 9181 H] .. अपीलाथ" /Appellant ""यथ"/Respondent Shri Kanchan Kaushal, Ar अपीलाथ" क" ओर से/By Appellant Shri P.K. Srihari, Cit-Dr ""यथ" क" ओर से/By Respondent 14-06-2018 सुनवाई क" तार"ख/Date Of Hearing 12-09-2018 घोषणा क" तार"ख/Date Of Pronouncement आदेश /O R D E R Per S.S.Godara:- This Assessee’S Appeal For Assessment Year 2012-13 Arises Against The Asstt. Commissioner Of Income Tax, Circle-2(2), Kolkata’S Assessment Order Dated 30.01.2017, Involving Proceedings Section 144C R.W. 143(3) Of The Income Tax Act, 1961; In Short ‘The Act’. 2. The Assessee Appellant’S First Substantive Ground Raised In The Instant Appeal Challenge Correctness Of Transfer Price Adjustment Amounting To ₹345,51,562/- In Course Of Assessment As Pertaining To Its International Transactions With Its Overseas Associate Enterprise (Ae). This Assessee Is A Company Providing Consultancy Including Tax & Regulatory Services. It Filed Its Return On 30.11.2012 Stating Total Income Of ₹51,62,16,310/-. This Followed Its Revised Return Dated 31.03.2014 Reducing Its Taxable Income To ₹49,87,12,700/-. The Assessing Officer Took Up Scrutiny. He Came Across

Section 144CSection 92C

providing consultancy including tax and regulatory services. It filed its return on 30.11.2012 stating total income of ₹51,62,16,310/-. This followed its revised return dated 31.03.2014 reducing its taxable income to ₹49,87,12,700/-. The Assessing Officer took up scrutiny. He came across ITA No.483/Kol/2017

D.C.I.T Cir - 6, Kolkata. vs. M/S Turner Morrison Ltd., Kolkata

In the result, the appeal of the Revenue as well as assessee both are partly allowed as indicated above

ITA 297/KOL/2013[2009-10]Status: DisposedITAT Kolkata12 Sept 2018AY 2009-10

Bench: Shri P.M. Jagtap & Shri S.S. Viswanethra Ravi

adjusting the same against the income from house property, the total income of Rs.1,28,10,165/- was declared by the assessee in the revised return of income filed for the year under consideration on 30.03.2010. During the course of assessment proceedings, the assessee was required by the Assessing Officer

M/S Sg Snacks India Pvt Ltd, Madurai vs. ITO Corp Ward 3, Madurai

ITA 412/CHNY/2018[2014-15]Status: DisposedITAT Chennai12 Sept 2018AY 2014-15

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.412/Chny/2018 "नधा"रण वष" / Assessment Year : 2014-15

For Appellant: Shri K. Rama Mohan, CAFor Respondent: Ms. S. Vijayaprabha, JCIT

Rama Mohan, the Ld. representative for the assessee, submitted that the assessee claimed additional depreciation of ₹ 2 I.T.A. No.412/Chny/18 84,16,727/- by filing revised return. According to the Ld. representative, in the original return, the assessee claimed depreciation of ₹67,58,435/-. The Assessing Officer disallowed the claim ... admittedly engaged in the business of manufacturing potato chips. The assessee claimed depreciation of ₹67,58,435/- in the original return. By way of revised return, the assessee also claimed additional depreciation of ₹84,16,727/-. The Assessing Officer disallowed the claim of the assessee on the ground that

Peejay Silk Mills, Mumbai vs. ITO WD 20(2)(1), Mumbai

The appeal stand partly allowed for statistical purposes

ITA 4912/MUM/2016[2011-12]Status: DisposedITAT Mumbai12 Sept 2018AY 2011-12

Bench: Shri Saktijit Dey, Jm & Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./I.T.A. No.4912/Mum/2016 (िनधा"रणवष" / Assessment Year: 2011-12) Peejay Silk Mills Income Tax Officer-20(2)(1) बनाम/ 3/37 Tardeo A.C. Market Piramal Chambers Mumbai-400 034 Lower Parel Vs. Mumbai-400 013 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaafp-6034-H (अपीलाथ"/Appellant) (""थ" / Respondent) :

For Appellant: R.K.Bothra, Ld.ARFor Respondent: Rajeev K. Gubgotra, Ld. DR
Section 143(3)Section 14A

against returned income of Rs.14.53 Lacs filed by the assessee on 31/03/2012 which was later revised at Rs.4.76 Lacs on 28/06/2012. In the revised return of income, the assessee has claimed set-off of loss under the head Income from Other Sources at higher figure of Rs.15.92 Lacs as against

DCIT 3(2)(2), Mumbai vs. National Bank of Agriculture An Rural Development, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 3649/MUM/2016[2006-07]Status: DisposedITAT Mumbai12 Sept 2018AY 2006-07

Bench: Shri B.R. Baskaran & Shri Pawan Singhdcit 3(2)(2) National Bank Of Agriculture & Room No. 674, 6Th Floor, Rural Development, C-24, Aayakar Bhavan, M.K. Road, Vs. G-Block, Bandra Kurla Complex, Mumbai-400020. Bandra, Mumbai-400051. Pan: Aaact4020G Appellant Respondent

For Respondent: Shri Abhijit Patankar (DR)
Section 143(3)Section 147Section 148Section 253Section 254(1)

restored." 2. Brief facts of the case are that the assessee filed its return of income for Assessment Year 2006-07 on 01.11.2006. The revised return was filed on 04.10.2007 which was again revised on 22.11.2007. The assessment was completed under section 143(3) on 30.11.2007. Subsequently, the assessment

M/S. Sukarma Finance (P) Ltd., New Delhi vs. JCIT, New Delhi

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

ITA 1743/DEL/2015[2009-10]Status: DisposedITAT Delhi12 Sept 2018AY 2009-10

Bench: Sh. R.K. Panda & Ms. Suchitra Kambleassessment Year: 2009-10 M/S. Sukarma Finance (P) Jcit Ltd. C/O 4832/24, Chamber Vs Circle – 9 (1) No.104, Prahlad House, C. R. Building Ansari Road, Darya Ganj, New Delhi -110002 New Delhi -110002 Pan Aaacs3512L (Appellant) (Respondent) Appellant By None Respondent By Sh. Anoop Singh, Sr Dr Date Of Hearing: 12/09/2018 Date Of Pronouncement: 12/09/2018 Order

Section 14Section 143Section 14ASection 271(1)

business of share trading. It filed its return of income on 30.09.2009 declaring loss of Rs.1,18,49,427/-. Subsequently the assessee filed a revised return on 26.09.2010 declaring a loss of Rs.90,76,803/-. The Assessing Officer completed the assessment u/s 143 (3) determining the total loss at loss

Arun Kumar Gupta (HUF), Delhi vs. ACIT, New Delhi

The appeal of the assessee is allowed

ITA 2990/DEL/2015[2010-11]Status: DisposedITAT Delhi11 Sept 2018AY 2010-11

Bench: Shri R. K. Panda & Ms Suchitra Kamblearun Kumar Gupta (Huf) Vs Acit 2122, Bahadurgarh Road, Circle-39(1) Sadar Bazar New Delhi Delhi (Respondent) Aafha4556G (Appellant)

Section 139(5)Section 142(1)Section 143(1)Section 143(2)Section 271Section 271(1)Section 271(1)(c)

left out from inclusion in the original computation and return of income. The rectification letter was filed since, the time limit for filing revised return under the provisions of section 139(5), had expired. The amount of capital gain was already included in the balance sheet submitted earlier

Humcha Impex Private Limited, Kolkata vs. ITO, WD-12(3), Kolkata

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

ITA 1413/KOL/2016[2009-10]Status: DisposedITAT Kolkata10 Sept 2018AY 2009-10

Bench: Shri P.M. Jagtap, Am & Shri A.T. Varkey, Jm] I.T.A. No. 1413/Kol/2016 Assessment Year: 2009-10 Humcha Impex Pvt. Ltd.....................…………………………………………..........................Appellant P-17, Kalakar Street, 3Rd Floor, Kolkata – 700 007. [Pan: Aabcc 3596 K] Ito Ward 12(3) Kolkata.............................................................................................Respondent P-7, Chowringhee Square, Kolkata – 700 069. Appearances By: Shri Saurabh Bagaria & Debosmita Mitra Advocate, Appearing On Behalf Of The Assessee. Shri Kapil Mondal, Jcit, Sr. Dr Appearing On Behalf Of The Revenue. Date Of Concluding The Hearing : September 10, 2018 Date Of Pronouncing The Order : September 10, 2018 Order Per P.M. Jagtap, Am This Appeal Filed By The Assessee Is Directed Against The Order Of Ld. Cit(A) – 4, Kolkata Dated 18.01.2018 Whereby He Confirmed All The 3 Additions Made By The Ao To The Total Income Of The Assessee.

Section 10ASection 10BSection 131Section 142(1)Section 143(2)Section 143(3)Section 68

subsequent notice u/s 142(1) did the assessee reverse its claim of deduction u/s 10AA to 10B of the Act without filing a revised return. Relying on the case law of Goetze (lndia) Ltd. vs. CIT (SC) 284 ITR 323, the claim was rejected  That compared with the certificate issued

Housing Development & Infrastructure Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle 5(4), Mumbai

In the result, appeal of the assessee is partly allowed as indicated above

ITA 5986/MUM/2017[2013-14]Status: DisposedITAT Mumbai10 Sept 2018AY 2013-14

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

For Appellant: Shri Dr. K. ShivaramFor Respondent: Shri Anadi Varma
Section 115JSection 143(3)Section 263Section 80

under normal provisions of the Act and book profits of ₹.20,37,91,742/- u/s.115JB of the Act. Later revised return was filed on 31.10.2013 declaring income of ₹.Nil under normal provisions of Act and book profits of ₹.Nil u/s.115JB of the Act. In the revised return filed, assessee written ... Housing Development and Infrastructure Limited explained why the unabsorbed cost was not claimed in the original return and claimed in the revised return. The Assessing officer was also of the view that since the assessee disputed the termination of the contract by MIAL the expenditure debited to P&L account

Sh. Dinesh Dua, Delhi vs. DCIT, Chandigarh

In the result, the appeal of the assessee is treated as partly

ITA 395/CHANDI/2016[2010-11]Status: DisposedITAT Chandigarh07 Sept 2018AY 2010-11

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaassessment Year : 2008-09

For Appellant: Sh. S.K. Bhasin, CAFor Respondent: Sh. Manoj Mishra, CIT-DR
Section 132Section 139(1)Section 143(2)Section 153ASection 24

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 ... return filed by the assessee u/s 153A declaring the additional income at the most can be said to be a revised return of income and the Assessing officer was required to look into each and every aspect of the income of the assessee including the exemptions or deductions as available

Sh.Dinesh Dua, Delhi vs. DCIT, Chandigarh

In the result, the appeal of the assessee is treated as partly

ITA 379/CHANDI/2016[2009-10]Status: DisposedITAT Chandigarh07 Sept 2018AY 2009-10

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaassessment Year : 2008-09

For Appellant: Sh. S.K. Bhasin, CAFor Respondent: Sh. Manoj Mishra, CIT-DR
Section 132Section 139(1)Section 143(2)Section 153ASection 24

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 ... return filed by the assessee u/s 153A declaring the additional income at the most can be said to be a revised return of income and the Assessing officer was required to look into each and every aspect of the income of the assessee including the exemptions or deductions as available

Shri Dinesh Dua, Delhi vs. DCIT, Chandigarh

In the result, the appeal of the assessee is treated as partly

ITA 378/CHANDI/2016[2007-08]Status: DisposedITAT Chandigarh07 Sept 2018AY 2007-08

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaassessment Year : 2008-09

For Appellant: Sh. S.K. Bhasin, CAFor Respondent: Sh. Manoj Mishra, CIT-DR
Section 132Section 139(1)Section 143(2)Section 153ASection 24

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 ... return filed by the assessee u/s 153A declaring the additional income at the most can be said to be a revised return of income and the Assessing officer was required to look into each and every aspect of the income of the assessee including the exemptions or deductions as available

S.T. Electricals Pvt. Ltd., Pune vs. Deputy Commissioner of Income-Tax

In the result, the impugned order is set aside and the appeal of assessee is allowed

ITA 831/PUN/2016[2009-10]Status: DisposedITAT Pune07 Sept 2018AY 2009-10

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri Pramod ShingteFor Respondent: Shri M.K. Verma
Section 139(1)Section 143(3)

assessment year 2009-10 on 17-07-2009 declaring total income of Rs.2,16,17,440/-. Thereafter, the assessee filed revised return of income on 12-03-2013 declaring income of Rs.4,15,55,520/-, thus, additional income of Rs.1,99,38,083/- was disclosed. The additional income declared

M/S Bannalal Jat Constructions Pvt. Ltd., Bhilwara vs. Assistant Commissioner of Income Tax, Central Circle, Ajmer

In the result, appeal of the assessee is allowed

ITA 477/JPR/2018[2012-13]Status: DisposedITAT Jaipur07 Sept 2018AY 2012-13
For Appellant: Shri P.C. Parwal (CA)For Respondent: Smt. Rolly Agarwal (CIT)
Section 132Section 143(2)Section 153A

153C cannot be interpreted to be a further innings for the AO and/or assessee beyond provisions of Sections 139 (return of income), 139(5) (revised return of income), 147 (income escaping assessment) and 263 (revision of orders) of the Act. 26. The plea raised on behalf of the assessee that

Gilbarco Veeder, Coimbatore vs. DCIT Cir 1(1)(2), Mumbai

In the result, the assessee’s appeal is allowed

ITA 2695/MUM/2017[2011-12]Status: DisposedITAT Mumbai07 Sept 2018AY 2011-12

Bench: Shri Shamim Yahya, Am & Shri Pawan Singh, Jm

For Appellant: Shri Ketan Ved/Ms. Urvi MehtaFor Respondent: Shri Abhijeet Patanker
Section 119(2)Section 119(2)(b)Section 139(1)Section 143(3)Section 44ASection 80

passed on 09.03.2015 which determined total loss of Rs.(-)35,69,59,530/- in which the loss in the revised return was restricted to Rs.(-)35,69,59,530/- which was the loss as per the original return filed by the assessee. 4. The Assessing Officer (‘A.O.’ for short ... loss of Rs. 35,69,59,530/- as against the loss provided by the assessee company of Rs.55,72,49,353/- as per the revised return. The AO is also of the opinion that as per Sec. 80 of the I.T. Act no loss is allowed to be carried

DCIT 3(2)(1), Mumbai vs. Mangalore Refinery and Petrochemicals Ltd, Mumbai

In the result the appeal filed by the revenue is dismissed

ITA 7241/MUM/2014[2009-10]Status: DisposedITAT Mumbai07 Sept 2018AY 2009-10

Bench: Shri Saktijit Dey () & Shri N.K. Pradhan () Assessment Year: 2009-10 Mangalore Refinery & Addl. Cit-3(2), Mumbai Petrochemicals Ltd. 15Th Vs. Floor, Maker Tower, Ewing, Cuffe Parade, Mumbai- 400005. Pan No. Aaacm5132A Respondent Appellant Assessment Year: 2009-10 Dcit-3(2) Room No. Mangalore Refinery & 674, 6Th Floor, Petrochemicals Ltd. 15Th Vs. Aayakarbhavan, M. K. Floor, Maker Tower, Ewing, Road, Mumbai-400020. Cuffe Parade, Mumbai- 400005. Pan No. Aaacm5132A Appellant Respondent Assessee By : Mr. J.D.J. Mistri, Senior Advocate & Mr. Madhur Agrawal, Advocate Revenue By : Mr.Samuel Darse, Cit(Dr) Date Of Hearing : 12/06/2018 Date Of Pronouncement: 07/09/2018

For Appellant: Mr. J.D.J. Mistri, Senior AdvocateFor Respondent: Mr.Samuel Darse, CIT(DR)
Section 143(3)Section 195Section 40Section 44B

issues are involved, we are proceeding to dispose them off by this consolidated order for the sake of convenience. The assessee-company filed its revised return of income for the assessment year (AY) 2009-10 on 29.03.2011 declaring total income of Rs.1565,34,24,281/- under normal provisions