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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

DCIT Cir 3(3)(1), Mumbai vs. Reliance Capital Ltd, Navi Mumbai

In the result, this appeal filed by the Revenue stands dismissed

ITA 4008/MUM/2016[2012-13]Status: DisposedITAT Mumbai07 Nov 2017AY 2012-13

Bench: Shri Shamim Yahya, Am & Shri Sandeep Gosain, Jm आयकर अपील सं./I.T.A. No.4008/Mum/2016 ("नधा"रण वष" / Assessment Year: 2012-13) Dy. Cit, Circle-3(3)(1), M/S. Reliance Capital Ltd. Room No. 609, 6Th Floor, H Block, 1St Floor, बनाम/ Aayakar Bhavan, M. K. Road, Dhirubhai Ambani Knowledge Vs. Mumbai-400 020 City, Koparkhairne, Navi Mumbai-400 710 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. Aaacr 5054 J (अपीलाथ" /Appellant) (""यथ" / Respondent) : अपीलाथ" क" ओर से / Appellant By : Shri M. V. Rajguru ""यथ" क" ओर से/Respondent By : Shri Jitendra Sanghavi सुनवाई क" तार"ख / : 26.10.2017 Date Of Hearing घोषणा क" तार"ख / : 07.11.2017 Date Of Pronouncement आदेश / O R D E R Per Shamim Yahya, A. M.: This Appeal By The Revenue Is Directed Against The Order By The Commissioner Of Income Tax (Appeals)-8, Mumbai (‘Cit(A)’ For Short) Dated 23.03.2016 & Pertains To The Assessment Year (A.Y.) 2012-13. 2. The Grounds Of Appeal Read As Under: 1. "Whether On The Facts & In The Circumstances Of The Case & In Law, Ld. Cit(A) Has Erred In Not Considering The Fact That The Amount Of Disallowance

For Appellant: Shri M. V. RajguruFor Respondent: Shri Jitendra Sanghavi
Section 115JSection 143(2)Section 14A

Rs.2,89,45,87,522/- and book loss u/s. 115JB at Rs.4,05,52,60,419/- on 29.09.2012. The assessee has filed the revised return on 10.03.2014 declaring current year’s loss at Rs.2,89,45,87,522/- under normal provisions and book profit u/s. 115JB at Rs.4 ... assessee filed the revised return to enhance the claim of the taxes deducted at source from Rs.1,32,39,02,794/- to Rs.1,43,27,76,489/-. Notices u/s. 143(2) and 142(1) was issued to the assessee. 4. During the course of assessment proceedings, the Assessing Officer observed

Chiron Behring Vaccines P.Ltd, Mumbai vs. Addl CIT RG 8(1), Mumbai

ITA 2637/MUM/2015[2008-09]Status: DisposedITAT Mumbai03 Nov 2017AY 2008-09
For Appellant: S/Shri Kamal Sawhney & Abhishek TilakFor Respondent: Shri V. Jenardhanan-CIT-DR
Section 143(3)Section 254(1)

business of manufacturing of rabies vaccine and filed its original return of income on 30/09/2008,declaring total income of Rs.30.15 crores.Later on, a revised return was filed on 18/03/2010 declaring total income of Rs.29.99 crores. 2.During the assessment proceedings,the AO found that the assessee had entered into inter - national

M/S Electronics & Controls Power Systems Pvt. Ltd., Bangalore vs. DCIT, Bangalore

In the result, appeal of the assessee is allowed

ITA 914/BANG/2016[2008-09]Status: DisposedITAT Bangalore03 Nov 2017AY 2008-09

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boazassessment Year : 2008-09

For Appellant: Shri. Gurunathan, AdvocateFor Respondent: Shri. Pradeep Kumar, CIT-DR
Section 139Section 139(1)Section 139(3)

income on 29.9.2009 which was within the time allowed u/s 139(1) of the Act and therefore, the return filed on 29.3.2011 was a revised return u/s 139(5) of the Act and therefore, the assessee is eligible for deduction u/s 80IA of the Act. 12. The Revenue also

M/S Infineon Technologies India Pvt. Ltd., Bangalore vs. Addl.C.I.T

In the result, both the appeals of the assessee and revenue for Assessment Year 2002-03 are allowed for statistical purposes

ITA 1760/BANG/2013[2002-03]Status: DisposedITAT Bangalore03 Nov 2017AY 2002-03

Bench: Shri George George K & Shri Jason P Boaz

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Smt. Padma Meenakshi, JCIT (D.R)
Section 10BSection 143(3)Section 92C

claiming deduction of Rs.59,53,692 under Section 10B of the Income Tax Act, 1961 (in short 'the Act'). The assessee, subsequently, filed a revised return of income on 13.11.2003 wherein the income declared was Rs.16,43,091; after claiming deduction of Rs.1,31,84,858 under Section

Sree Kailai Spinners P Ltd., Coimbatore vs. ITO, Coimbatore

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

ITA 1226/CHNY/2017[2013-14]Status: DisposedITAT Chennai02 Nov 2017AY 2013-14

Bench: Shri N.R.S. Ganesan & Shri Sanjay Arora

For Appellant: Shri S. Sendamarai Kannan, AdvocateFor Respondent: Shri N. Madhavan, Addl. CIT
Section 139(4)Section 80

under Section 80-IA of the Income- tax Act, 1961 (in short 'the Act') in respect of income generated from windmill. While filing the revised return on 19.12.2013, according to the Ld. counsel, the assessee has not claimed deduction under Section 80-IA of the Act since the income ... assessed only in the assessment year 2014-15, therefore, the deduction under Section 80-IA of the Act was not claimed in the revised return. However, the Assessing Officer found that the income of `60,81,004/- generated from operation of windmill has to be assessed in the year under

DCIT, Cir-2, Siliguri vs. Shri Suresh Karmakar, Siliguri

In the result, the appeal of the Revenue is dismissed

ITA 1399/KOL/2015[2010-2011]Status: DisposedITAT Kolkata01 Nov 2017AY 2010-2011

Bench: Hon’Ble Shri M.Balaganesh, Am & Shri S.S.Viswanethra Ravi, Jm] I.T.A No. 1399/Kol/2015 Assessment Year : 2010-11 Dcit, Circle-2, Siliguri -Vs- Shri Suresh Karmakar [Pan: Alipk 6761 D] (Appellant) (Respondent)

For Appellant: Shri Avinash Mishra, CITFor Respondent: Shri S.M. Surana, Advocate
Section 132(4)Section 143(3)Section 271(1)(c)Section 271A

offer the same in the original return of income filed for the assessment year 2010-11 on 30.08.2011. This return was also followed by revised return. Even in this revised return, the assessee did not offer this undisclosed income of Rs. 3 crores. However, the assessee later on filed second ... revised return on 01.11.2011 wherein he duly offered additional income Rs. 2,90,74,000/- for assessment year 2010-11 and Rs. 9,26,000/- for assessment year 2008- 09. The assessee also filed revised return for assessment year 2008-09 including the additional income

R.Vasuki, Coimbatore vs. DCIT, Coimbatore

In the result, the assessee’s appeal is dismissed

ITA 899/CHNY/2015[2010-11]Status: DisposedITAT Chennai01 Nov 2017AY 2010-11

Bench: Shri Sanjay Arora & Shri Duvvuru Rl Reddy

For Appellant: Mrs. Veni Raj, Jt. CITFor Respondent: 03.08.2017
Section 131Section 133ASection 139(5)Section 143(3)Section 148Section 271(1)(c)

original return filed on 30.08.2010 at an income of ". 24,05,255/-. The said ‘revision’ being beyond the time prescribed for filing a revised return u/s. 139(5), the same was regularized by the issue of notice u/s. 148 on 08.01.2014, and assessed as income vide order ... sought to be evaded, which is the subject matter of dispute between the parties. While the assessee insists that her action in filing the ‘revised return’ was done only to purchase peace with the IT Department and avoided protracted litigation, i.e., is voluntary, with nothing adverse having been found against

Capitol Fibres Pvt. Ltd., Thane vs. ITO Ward, 1(3), Thane

Appeal stands partly allowed

ITA 2597/MUM/2016[2011-12]Status: DisposedITAT Mumbai01 Nov 2017AY 2011-12

Bench: Shri D.T. Garasia, Jm & Shri Manoj Kumar Aggarwal, Am आयकर अपील सं./I.T.A. No.2597/Mum/2016 (िनधा"रण वष" / Assessment Year: 2011-12) Capitol Fibers Private Limited Income Tax Office Ward 1(3) बनाम/ Plot No.C-30,Road No.16 Mumbai Wagle Industrial Estate Vs. Thane-400 604 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. Aaacc-6928-J (अपीलाथ" /Appellant) (""थ" / Respondent) :

For Appellant: Dr. P.Daniel ,Ld.ARFor Respondent: V.Jenardhanan, Ld. Sr. DR
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

placed on record substantiate the same since it is observed that the assessee has reversed VAT credit of Rs.5,62,648/- in subsequent revised return. Hence, the addition is estimated on net alleged bogus purchases i.e. Rs.1,28,06,504/- less Rs.5,62,648/-. Resultantly, the addition is restricted

DCIT CC 3(4) Cen RG 3, Mumbai vs. Dhanvinder Bindra, Mumbai

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

ITA 5699/MUM/2015[2007-08]Status: DisposedITAT Mumbai01 Nov 2017AY 2007-08

Bench: Shri P K Bansal & Shri R.L. Negi

For Appellant: Shri Purushottam KumarFor Respondent: Shri Neel Khandelwal
Section 132Section 143(3)Section 153ASection 271Section 271(1)Section 271(1)(c)

offered. Had the above incomes left by oversight, the assessee would have offered the same any time after filing of return by filing revised return. The assessee’s act clearly shows his intention of evading tax by not disclosing his above incomes either in return of income or by filing ... revised return later on. Even during assessment proceedings, the assessee has not voluntarily offered the same for taxation. It was only when queried by the AO that the assessee offered the incomes and filed revised computation of income. From the above facts and by the conduct of the assessee, mens

DCIT CC 3(4) Cen RG 3, Mumbai vs. Dhanvinder Bindra, Mumbai

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

ITA 5698/MUM/2015[2006-07]Status: DisposedITAT Mumbai01 Nov 2017AY 2006-07

Bench: Shri P K Bansal & Shri R.L. Negi

For Appellant: Shri Purushottam KumarFor Respondent: Shri Neel Khandelwal
Section 132Section 143(3)Section 153ASection 271Section 271(1)Section 271(1)(c)

offered. Had the above incomes left by oversight, the assessee would have offered the same any time after filing of return by filing revised return. The assessee’s act clearly shows his intention of evading tax by not disclosing his above incomes either in return of income or by filing ... revised return later on. Even during assessment proceedings, the assessee has not voluntarily offered the same for taxation. It was only when queried by the AO that the assessee offered the incomes and filed revised computation of income. From the above facts and by the conduct of the assessee, mens

DCIT CC 3(4) Cen RG 3, Mumbai vs. Dhanvinder Bindra, Mumbai

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

ITA 5697/MUM/2015[2005-06]Status: DisposedITAT Mumbai01 Nov 2017AY 2005-06

Bench: Shri P K Bansal & Shri R.L. Negi

For Appellant: Shri Purushottam KumarFor Respondent: Shri Neel Khandelwal
Section 132Section 143(3)Section 153ASection 271Section 271(1)Section 271(1)(c)

offered. Had the above incomes left by oversight, the assessee would have offered the same any time after filing of return by filing revised return. The assessee’s act clearly shows his intention of evading tax by not disclosing his above incomes either in return of income or by filing ... revised return later on. Even during assessment proceedings, the assessee has not voluntarily offered the same for taxation. It was only when queried by the AO that the assessee offered the incomes and filed revised computation of income. From the above facts and by the conduct of the assessee, mens

DCIT CC 3(4) Cen RG 3, Mumbai vs. Dhanvinder Bindra, Mumbai

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

ITA 5696/MUM/2015[2004-05]Status: DisposedITAT Mumbai01 Nov 2017AY 2004-05

Bench: Shri P K Bansal & Shri R.L. Negi

For Appellant: Shri Purushottam KumarFor Respondent: Shri Neel Khandelwal
Section 132Section 143(3)Section 153ASection 271Section 271(1)Section 271(1)(c)

offered. Had the above incomes left by oversight, the assessee would have offered the same any time after filing of return by filing revised return. The assessee’s act clearly shows his intention of evading tax by not disclosing his above incomes either in return of income or by filing ... revised return later on. Even during assessment proceedings, the assessee has not voluntarily offered the same for taxation. It was only when queried by the AO that the assessee offered the incomes and filed revised computation of income. From the above facts and by the conduct of the assessee, mens

DCIT CC 3(4) Cen RG 3, Mumbai vs. Dhanvinder Bindra, Mumbai

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

ITA 5695/MUM/2015[2003-04]Status: DisposedITAT Mumbai01 Nov 2017AY 2003-04

Bench: Shri P K Bansal & Shri R.L. Negi

For Appellant: Shri Purushottam KumarFor Respondent: Shri Neel Khandelwal
Section 132Section 143(3)Section 153ASection 271Section 271(1)Section 271(1)(c)

offered. Had the above incomes left by oversight, the assessee would have offered the same any time after filing of return by filing revised return. The assessee’s act clearly shows his intention of evading tax by not disclosing his above incomes either in return of income or by filing ... revised return later on. Even during assessment proceedings, the assessee has not voluntarily offered the same for taxation. It was only when queried by the AO that the assessee offered the incomes and filed revised computation of income. From the above facts and by the conduct of the assessee, mens

DCIT CC 3(4) Cen RG 3, Mumbai vs. Dhanvinder Binddra, Mumbai

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

ITA 5694/MUM/2015[2002-03]Status: DisposedITAT Mumbai01 Nov 2017AY 2002-03

Bench: Shri P K Bansal & Shri R.L. Negi

For Appellant: Shri Purushottam KumarFor Respondent: Shri Neel Khandelwal
Section 132Section 143(3)Section 153ASection 271Section 271(1)Section 271(1)(c)

offered. Had the above incomes left by oversight, the assessee would have offered the same any time after filing of return by filing revised return. The assessee’s act clearly shows his intention of evading tax by not disclosing his above incomes either in return of income or by filing ... revised return later on. Even during assessment proceedings, the assessee has not voluntarily offered the same for taxation. It was only when queried by the AO that the assessee offered the incomes and filed revised computation of income. From the above facts and by the conduct of the assessee, mens

Mettaco Engineering P.Ltd, Mumbai vs. ITO 6(3)(3), Mumbai

Appeal stands allowed for statistical purposes in terms of our above order

ITA 4274/MUM/2015[2010-11]Status: DisposedITAT Mumbai01 Nov 2017AY 2010-11

Bench: Shri D.T. Garasia, Jm & Shri Manoj Kumar Aggarwal, Am आयकर अपील सं./I.T.A. No.4274/Mum/2015 (िनधा"रण वष" / Assessment Year: 2010-11) Mettaco Engineering Private Income Tax Officer 6(3)(3) Limited Mumbai बनाम/ 306,Pragati Industrial Estate, N.M.Joshi Marg Vs. Lower Parel(East) Mumbai-400 013 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. Aabcm-8653-K (अपीलाथ" /Appellant) (""थ" / Respondent) :

For Appellant: Snehal Shah ,Ld.ARFor Respondent: Suman Kumar , Ld. DR
Section 143(3)

have also noted that initially the blank return of income was filed by the assessee which, during scrutiny assessment, has been revised altogether. No revised return was filed by the assessee despite having sufficient timeline available with him. Prima Facie, the conduct of the assessee do not justify granting

ACIT, New Delhi vs. Shri Pavel Garg, New Delhi

The appeal of the department stands partly allowed for statistical purposes in terms of our observations

ITA 5381/DEL/2011[2008-09]Status: DisposedITAT Delhi01 Nov 2017AY 2008-09

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Rakesh Gupta, AdvocateFor Respondent: Shri Atiq Ahmod, Sr. DR
Section 139(5)Section 143(3)

respect of insurance claim it was submitted that the same were claimed by the assessee by simply filing revised computation of income and no revised return of income was filed. It was submitted that such a claim could only be made through filing of revised return of income ... assessee filed revised computation of income claiming non-accrual of the insurance claim and interest thereon. However, the AO rejected the claim because revised return of income was not filed within the stipulated time, as laid down in the Act, and the AO was of the opinion that such deduction

ACIT 3(1)(1), Mumbai vs. B Arunumar Capital & Credit Services P.Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 4147/MUM/2016[2011-12]Status: DisposedITAT Mumbai31 Oct 2017AY 2011-12

Bench: Shri B.R. Baskaran (Am) & Shri Ravish Sood(Jm)

Section 14A

India Ltd. (284 ITR 323), took the view that the revised claim can be admitted only if it is made by way of filing revised return of income. Accordingly he disallowed the sum of ` 55.56 lakhs, as originally worked out by the assessee, u/s. 14A of the Act. The learned ... Rules . In this context, the CIT(A) has noticed that assessee was entitled to raise a fresh claim even otherwise than through a revised return. The CIT(A) observed that the claim of the assessee has been rejected on mere technicalities as the fresh claim was made through a written

DCIT, New Delhi vs. M/S. Bokaro Power Supply Co. Ltd., New Delhi

In the result, appeal of the assessee is partly allowed whereas the appeal of the Revenue is dismissed

ITA 3692/DEL/2014[2010-11]Status: DisposedITAT Delhi31 Oct 2017AY 2010-11

Bench: Sh. Amit Shukla & Sh. O.P. Kantassessment Year: 2010-11 Vs. Dcit, Circle -3(1), New Delhi M/S. Bokaro Power Supply Co. Ltd., Ispat Bhavan, Lodhi Road, New Delhi Pan : Aabcb8976G (Appellant) (Respondent) & Assessment Year: 2010-11 Vs. M/S. Bokaro Power Supply Co. Dcit, Circle -3(1), New Delhi Ltd., 4Th Floor, Ispat Bhavan, Lodhi Road, New Delhi Pan : Aabcb8976G (Appellant) (Respondent) Assessee By Sh. M.P. Rastogi, Adv. & Sh. Anil Sharma, Agm Respondent By Sh. Sandip Kumar Mishra, Sr.Dr Date Of Hearing 11.10.2017 Date Of Pronouncement 31.10.2017 Order Per O.P. Kant, A.M.:

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

fails to furnish any return by the prescribed date as required under sub- Section (2) of Section 29; or (c) being required to furnish revised return, fails to furnish the revised return by the date prescribed under sub-section (3) of Section 29; (d) the prescribed authority shall, after giving ... rupees five thousand in a year. Explanation – Return for this purpose shall mean and include the Monthly Abstract, Return for any tax period, Revised Return(s) as well as the Annual Return.” 6.8 It is evident from clear language of the relevant section that the penalty levied is not compensatory

Bokaro Power Supply Co. Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeal of the assessee is partly allowed whereas the appeal of the Revenue is dismissed

ITA 3405/DEL/2014[2010-11]Status: DisposedITAT Delhi31 Oct 2017AY 2010-11

Bench: Sh. Amit Shukla & Sh. O.P. Kantassessment Year: 2010-11 Vs. Dcit, Circle -3(1), New Delhi M/S. Bokaro Power Supply Co. Ltd., Ispat Bhavan, Lodhi Road, New Delhi Pan : Aabcb8976G (Appellant) (Respondent) & Assessment Year: 2010-11 Vs. M/S. Bokaro Power Supply Co. Dcit, Circle -3(1), New Delhi Ltd., 4Th Floor, Ispat Bhavan, Lodhi Road, New Delhi Pan : Aabcb8976G (Appellant) (Respondent) Assessee By Sh. M.P. Rastogi, Adv. & Sh. Anil Sharma, Agm Respondent By Sh. Sandip Kumar Mishra, Sr.Dr Date Of Hearing 11.10.2017 Date Of Pronouncement 31.10.2017 Order Per O.P. Kant, A.M.:

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

fails to furnish any return by the prescribed date as required under sub- Section (2) of Section 29; or (c) being required to furnish revised return, fails to furnish the revised return by the date prescribed under sub-section (3) of Section 29; (d) the prescribed authority shall, after giving ... rupees five thousand in a year. Explanation – Return for this purpose shall mean and include the Monthly Abstract, Return for any tax period, Revised Return(s) as well as the Annual Return.” 6.8 It is evident from clear language of the relevant section that the penalty levied is not compensatory

Phonix Lamps Ltd vs. Addl CIT Range

The appeal of the assessee stands allowed

ITA 2845/DEL/2007[2003-2004]Status: DisposedITAT Delhi31 Oct 2017AY 2003-2004

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishiassessment Year : 2003-04 M/S Pheonix Lamps Ltd., Vs Addl. Cit, 59A, Nsez, Phase-Ii, Range Noida. Noida. (Appellant) (Respondent) Appellant By :S/Shri Shashwat Bajpai, Sharat Agrawal, Adv. Respondent By : Shri Atiq Ahmad, Sr. Dr Date Of Hearing: 03.08.2017 Date Of Pronouncement: 31.10.2017 O R D E R

For Appellant: S/Shri Shashwat Bajpai, Sharat Agrawal, AdvFor Respondent: Shri Atiq Ahmad, Sr. DR
Section 10ASection 10A(6)

Therefore, after adjusting the set off of depreciation allowance already allowed amounting to Rs. 5,38,447/-, the assessee filed revised return of income claiming setoff of brought forward depreciation amounting to Rs. 10,27,69,533/-. 2.1 The assessee was entitled to special deduction under section