“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

Law Charter, Mumbai vs. Asst CIT Cir 11(2), Mumbai

In the result, appeal of the assessee in ITA No

ITA 4875/MUM/2016[2010-11]Status: DisposedITAT Mumbai21 Apr 2017AY 2010-11

Bench: Shri Mahavir Singh & Shri Ramit Kocharआयकर अपील सं./I.T.A. No. 4875/Mum/2016 ("नधा"रण वष" / Assessment Year : 2010-11) Law Charter, The Asstt. Comm. Of बनाम/ 1, Raja Bahadur Mansion, Income Tax – Circle 11(2), V. Hanuman Street, Fort, Aayakar Bhavan, Mumbai– 400 023. M.K. Road, Mumbai 400 020. "थायी लेखा सं./Pan : Aabfl 2094 G (अपीलाथ" /Appellant) .. (""यथ" / Respondent)

For Appellant: Shri V.J. AsraniFor Respondent: Shri Sunil Kumar Agarwal

Section 143(3)Section 37

agreement with the AO that the claim which was not made in the original return cannot be claimed by way of revised return as held by the Supreme Court in the case of Goetze India Ltd. 284 ITR 323(Supreme Court). The case laws relied by the appellant cannot ... adjudicating the appeal for assessment year 2008-09. The fresh claim albeit which was not made before the AO vide return of income including revised return of income can be made in the appellate proceedings as per ratio of law laid down by Hon’ble Bombay High Court

Robin Bipin Mehta, Mumbai vs. ACIT CC 20, Mumbai

In the result, appeal of the assessee is allowed

ITA 4270/MUM/2016[2011-12]Status: DisposedITAT Mumbai21 Apr 2017AY 2011-12

Bench: Shri R.C.Sharma, Am Mr. Robin Bipin Mehta Vs. Acit- Cc-20, Mumbai – 3, Deepak, 1St Floor, 401, 400 021 S.V.Road, Vile Parle (West) Mumbai – 400 056 Pan/Gir No. Aabpm8343D Appellant) .. Respondent)

Section 132(1)Section 139Section 139(1)Section 143(3)Section 153ASection 153A(1)Section 271(1)(c)

appeal filed by the Department, the High Court held as under:- "21. Thus, it is clear that when the A.O has accepted the revised return filed by the assessee under section 153A, no occasion arises to refer to previous return filed under Section ... gives him an opportunity to make good omission, if any, in the original return. Once the A.O accepts the 4 Mr. Robin Bipin Mehta revised return filed under Section 153A, the original return under Section 139 abates and becomes non - est. Now, it is trite to say that the "concealment

Patman & G. Hospitality P.Ltd, Mumbai vs. ITO 7(1)(3), Mumbai

In the result, appeal of the assessee is allowed in part

ITA 889/MUM/2013[2009-10]Status: DisposedITAT Mumbai21 Apr 2017AY 2009-10

Bench: Shri R.C.Sharma, Am & Shri Ram Lal Negi, Jm M/S. Patman & G.Hospitality Vs. Ito – 7 (1)-3, Mumbai Pvt. Ltd., 38, Kakad Udyog Bhavan, L.J.Cross Road No.1, Mahim (W), Mumbai – 400 016 Pan/Gir No. Aacp1821B Appellant) .. Respondent)

Section 143(3)Section 50B

till after the date of filing of the return as the matter was still pending. In October 2010, Aramark India Private Limited filed a revised return of TDS and the interest and TDS was reflected in the 26 AS report from then onward. Thus the assessee company has not erred

M/S I2 Technolgoies Software Pvt Ltd, Bangalore vs. Commissioner of Income Tax (Appeals)IV, Bangalore

In the result, the appeal of the revenue is partly allowed for statistical

ITA 1207/BANG/2014[2003-04]Status: DisposedITAT Bangalore21 Apr 2017AY 2003-04

Bench: Shri A. K. Garodia & Shri Laliet Kumar

For Appellant: Shri Arvind Sonde, AdvocateFor Respondent: Shri G.R.Reddy, CIT –I

Section 92C

this case, the facts and dispute were different. In that case, the commission expenses were suo motu disallowed by the assessee in the revised return and the assessee also had paid the due taxes on that. Under these facts, it was held that the same cannot be considered as part ... operating expenses while computing the ALP. Therefore, it was held that if they are subsequently, disallowed suo moto by the assessee in the revised return, they are required to be excluded from the operating cost. In view of these facts of that case, this Tribunal order is not relevant

Rajendra Bhandari, New Delhi vs. ACIT, Faridabad

In the result, the appeal of the assessee is allowed

ITA 5749/DEL/2014[2006-07]Status: DisposedITAT Delhi21 Apr 2017AY 2006-07

Bench: Shri B.P. Jainassessment Years 2006-07 Vs. Acit, Central Circle-Ii, Alok Bhandari, 1/2873, Ram Nagar Extn. Faridabad. Loni Road, Shadara, New Delhi. Pan: Agmpb 5584A (Appellant) (Respondent) Assessment Years 2006-07 Rajendra Bhandari, Vs. Acit, Central Circle-Ii, 1/2873, Ram Nagar Extn. Faridabad. Loni Road, Shadara, New Delhi. Pan: Agmpb 5581F (Appellant) (Respondent) Assessee(S) By : Shri R.S. Ahuja, C.A.. Revenue By : Ms. Bedobani, Sr.D.R.

For Respondent: Ms. Bedobani, Sr.D.R

Section 133A(1)Section 139Section 139(1)Section 153ASection 153A(1)(b)Section 271(1)Section 271(1)(c)

under section 271(1)(c) of the Act could be levied for assessment years 1985-86, 1986-87 and 1987-88 even though the revised returns were filed offering the additional income after search and in response to notice under section 148.of the Act issued by the Department?" The Court ... above question in the affirmative. The Court held that no penalty uls 271(1)(c) of the Act could be levied where the revised return had been accepted and assessed at the hands of the appellant although the revised returns had been filed after a search under section

Alok Bhandari, New Delhi vs. ACIT, Faridabad

In the result, the appeal of the assessee is allowed

ITA 5747/DEL/2014[2006-07]Status: DisposedITAT Delhi21 Apr 2017AY 2006-07

For Respondent: Ms. Bedobani, Sr.D.R

Section 133A(1)Section 139Section 139(1)Section 153ASection 153A(1)(b)Section 271(1)Section 271(1)(c)

M/S. Oakland Bottlers (P) Ltd., New Delhi vs. ACIT, New Delhi

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

ITA 5565/DEL/2014[2009-10]Status: DisposedITAT Delhi21 Apr 2017AY 2009-10

Bench: Shri B.P. Jainassessment Year 2009-10 Oakland Bottlers (P) Ltd. Vs. Acit, Circle-13(1), 10/46A, West Punjabi Bagh, New Delhi. New Delhi. Pan: Aaaco 4250B (Appellant) (Respondent)

For Respondent: S/Shri Gautam Jain and Piyush

Section 139(1)Section 234BSection 801Section 801BSection 80I

with acknowledgement no.104445601301209. The acknowledgement of the return shows the return filed under the said acknowledgement to be a revised return. The assessee was required to explain as to why the deduction claimed u/s. 80IB may not be withdrawn on account of following reasons. i. In the preceding assessment years ... learned CIT(A) is reversed accordingly. 9. As regards the issue with regard to the filing of the original return and 8 the revised return. It was pointed out by the learned counsel for the assessee Mr. Gautam Jain, Advocate that original return was filed on 30th September

DCIT, New Delhi vs. Sh. Dinesh Shrama, New Delhi

In the result, the appeal of the Revenue is partly allowed for

ITA 226/DEL/2013[2008-09]Status: DisposedITAT Delhi21 Apr 2017AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh.Anadee Nath Misshra

Section 133Section 139Section 139(1)Section 139(4)Section 139(5)Section 143(3)Section 28Section 34Section 48

empowered under the Act reduce the returned income of Assessee after expiry of period specified u/s 1339(5) and without any revised returned filed by assessee u/s 139(5) of the Act. 3. Whether the Ld.CIT(A) is justified on merits in holding that indexation should be given from ... Ld.CIT(A) by pointing out that period specified u/s 139(5) of I.T.Act had expired and the assessee had not filed any revised return. The aforesaid amount of Rs.79,32,289/- was shown by the assessee as taxable income in the return filed by the assessee

DCIT, New Delhi vs. M/S. Federal Mogul Goetze India Ltd., Delhi

In the result, both the appeals filed by the revenue are dismissed

ITA 3441/DEL/2014[2004-05]Status: DisposedITAT Delhi20 Apr 2017AY 2004-05

Bench: Shri N.K. Saini & Shri Amit Shukla

For Appellant: Sh. Pradeep Dinsdia, AdvocateFor Respondent: Sh. Anil Kumar Sharma, Sr. DR

Section 143(1)Section 143(3)Section 144Section 147Section 147oSection 263Section 43Section 43BSection 44A

income on 30.10.2004 for the A.Y. 2004-05, declaring income of Rs. 4,15,84,748/- which was processed u/s 143(1). Later on, revised return of income was filed on 29.3.2006 which was also processed on 31.3.2006. The said revised return was selected for scrutiny and consequently, assessment order

Swastika Mukherjee, Kolkata vs. ITO, WD-55(4), Kolkata

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

ITA 257/KOL/2015[2008-2009]Status: DisposedITAT Kolkata19 Apr 2017AY 2008-2009

Bench: Us Has Not Pressed Ground No.2 I.E An Addition Of Rs.68,448/- Treating The Same As Undisclosed Income Being Deposit In Uco Bank Account. Hence, The Same Needs No Adjudication By Us Being Not Pressed. Accordingly, This Ground Of Assessee’S Appeal Is Dismissed.

Section 131

pertinent to note that the AO observed that in respect of allowance of expenditure as claimed and filed by the assessee that unless a revised return is filed by the assessee, the expenditure, if any, as claimed for deduction by the assessee cannot be allowed by following the order ... Supreme Court in the case of Goetze (I) Ltd Vs. CIT reported 229 ITR 383 (SC) and while the assessee did not file any revised return for claim of considered/entertained. Thus, he added the amount of Rs.13,44,314/- being undisclosed income of assessee to her total income

Tecnimont Icb Pvt. Ltd, Mumbai vs. The ACIT, Circle 9(3), Mumbai

ITA 1380/MUM/2009[2004-2005]Status: DisposedITAT Mumbai19 Apr 2017AY 2004-2005

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Manjunatha Swamy-CIT-DR

Section 10BSection 10B(4)Section 115Section 115JSection 143Section 254(1)Section 263

construction activities, filed its return of income on 29/10/2004, declaring loss at Rs.93.92 lakhs and book profit u/s.115 JB at Rs.18.18 lakhs.Subsequently,a revised return was filed on 28/09/2005,declaring Loss of Rs.1.67 croresand book profit at Rs. 18,18,098/-.The Assessing Officer(AO)completed the assessment

M/S. Satnam Overseas Exports, New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is allowed

ITA 4486/DEL/2016[2010-11]Status: DisposedITAT Delhi19 Apr 2017AY 2010-11

Bench: Shri B.P. Jainassessment Years 2010-11 Satnam Overseas Exports, Vs. Dcit, Central Circle- 201, Vipps Centre, 2- 28, Community Complex, New Delhi. Masjid Moth, Gk-Ii, New Delhi. Pan: Aacfs 5863 P (Appellant) (Respondent) Assessee(S) By : Ms. Ananya Kapoor & Shri Sanat Kapoor, Adv. Revenue By : Ms. Bedobani Chaudhuri, Sr.D.R. सुनवाई क" तार"ख/Date Of Hearing : 18/04/2017 घोषणा क" तार"ख /Date Of Pronouncement: 19/04/2017 Order This Appeal Of The Assessee Arises From The Order Of Learned Cit(A)- Xix, New Delhi, Vide Order Dated 21.06.2016 For The Assessment Year 2010- 11. 2. The Assessee Has Raised As Many As Eleven Grounds Of Appeal. As A Matter Of Fact The Learned Counsel For The Assessee, Ms. Ananya Kapoor, Adv. Pressed Only Ground Nos. 3, 4 & 5 Which Pertained To One Issue Only & The Said Grounds Are Reproduced Hereinbelow. “3. That The Cit(A) Has Erred In Law & On Facts In Holding That No Cognizance Can Be Taken Of The Claim Made By The Assessee That Sale Of Property Be Treated As Capital Gain & Indexation Benefit Should Be Allowed To The Assessee. The Action Of The Cit(A) In Rejecting The Claim Is Illegal & Bad In Law. 4. That The Cit(A) Has Erred In Law & On Facts In Holding That The Assessee Did Not Acquire Any Capital Asset & Hence Did Not Acquire Any Rights Over The Property. 5. The Interpretation Given By The Cit(A) Is Illegal, Bad In Law, Contrary To The Judgments & Well Settled Principles Of Law. Moreover The Cit(A) Has Failed To Examine The Material On Record In A Judicious Manner.” 2

For Respondent: Ms. Bedobani Chaudhuri

Section 10Section 10(33)Section 139(5)Section 143(2)(ii)

Income Tax Act, 1961(Act) and claim of business loss of Rs.85,18,854/- should be rejected as no revised return was filed under Section 139(5) of the Act. 3 2. It is an accepted position that the assessee had not claimed the said deduction or business loss ... speculative loss. 3. The claims were rejected by the Assessing Officer on three grounds that the respondent-assessee had not filed a revised return within the time allowed under Section 139(5) of the Act; dividend was received from Sun F&C Mutual Fund, which was not included

Navnitlal K Parikh, Mumbai vs. ACIT CC-45, Mumbai

The appeal of the assessee is allowed

ITA 6820/MUM/2008[2004-2005]Status: DisposedITAT Mumbai18 Apr 2017AY 2004-2005

Bench: Shri Joginder Singh & Shri Ramit Kocharassessment Years: 2004-05 Mr. Navnitlal K. Parikh, Acit, F-2, 77 & 78 Gujrati Society Cc-45, बनाम/ Nehru Road, Vile Parle (E), Aayakar Bhavan, Vs. Mumbai-400057 M.K. Road, Mumbai-400020 ("नधा"रती/Assessee) (राज"व /Revenue) Pa No.:-Aaccp6245F "नधा"रती क" ओर से / Assessee By Shri Shailesh Parmar Shri Suman Kumar-Dr राज"व क" ओर से / Revenue By 05/04/2017 सुनवाई क" तार"ख / Date Of Hearing : 18/04/2017 आदेश क" तार"ख /Date Of Order: Mr. Navnitlal K. Parikh

Section 139Section 15Section 153ASection 271(1)Section 271(1)(C)Section 271(1)(c)Section 5

asked the assessee to produce Shri ChampakLal Parekh to prove the creditworthiness and genuineness of gift. At this stage, the assessee filed a revised return and offered the said gift amount of Rs. 9, 25, 000/- to tax. 3.4 The Assessing Officer was of the view that the revised return ... submitted that the assessee has categorically stated that the said paper does not belong to the assessee. 4.2 As regards the revised return filed for the assessment year 2004- 05, the ld AR of the assessee has referred the provisions of section 153A and submitted that as per clause

Orix Auto Infrastructure Services Ltd, Mumbai vs. DCIT 10(3)(1), Mumbai

ITA 4480/MUM/2016[2011-12]Status: HeardITAT Mumbai17 Apr 2017AY 2011-12

Bench: Shri D.T. Garasia, Jm & Shri Manoj Kumar Aggarwal, Am आयकर अपील सं./I.T.A. No. 4480/Mum/2016

For Appellant: Dr. Anupama Singla, Ld. DR

Section 115JSection 143(3)Section 14A

disallowance made by the assessee suo-moto in the return of income and what assessee is seeking is revision of income without filing revised return of income which was not permissible as per the ruling of Apex Court in Goetze (India) Ltd. Vs CIT [284 ITR 323]. Moreover, the acceptance ... assessee’s claim would have resulted into amendment / lowering of income beyond returned income which was not possible without filing a revised return of income. Further, the assessee never raised this issue before Ld. AO and contested the same for the first time before Ld. CIT(A) whereas the issue

Savita Somchand Shah, Thane vs. Asst CIT Cir 1, Kalyan

ITA 4197/MUM/2016[2009-10]Status: DisposedITAT Mumbai17 Apr 2017AY 2009-10

Bench: Shri D.T. Garasia, Jm & Shri Manoj Kumar Aggarwal, Am

For Appellant: Dr. Anupama Singla, Ld. DR

Section 143(3)Section 271Section 271(1)(c)Section 274

filed by assessee on 10/02/2010 which was later revised to Rs.11,46,280/- on 31/03/2010. Since, the original return was filed belatedly, the revised return was treated as non-est by the Ld. AO. The assessee suffered addition of Rs.9,02,693/- on account of sale of certain shares against ... Rs.2,94,617/- u/s 271(1)(c) vide AO penalty order dated 16/05/2012. The assessee contended that it already offered the income in the revised return and paid due taxes thereupon and hence not liable for penalty. However not convinced, AO levied the impugned penalty, which upon appeal, was confirmed

Open Solutions Software Services Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result appeal of the assessee is partly allowed

ITA 7078/DEL/2014[2010-11]Status: DisposedITAT Delhi17 Apr 2017AY 2010-11

Bench: Sri J.Sudhakar Reddy & Sri Amit Shuklain Ita No. 7078/Del/2014 Ay: 2010-11

For Appellant: Sh. Sachit Jolly, AdvFor Respondent: Sh. T.M.Shiva Kumar, CIT(DR)

Section 143(3)Section 144(5)

accepted revised computation of book profit, only on the ground that the assessee has not filed any revised return of income for making such a claim. In coming to this conclusion the AO had strongly relied upon the decision of Hon’ble Supreme Court in the case of Goetz India ... delete the said adjustment and did not accept the assessee’s revised computation on the ground that the assessee has not filed the revised return of income. Even though the A.O. could not have entertained the said claim but it does not impinge upon the appellate authorities to entertain such

M/S. Rex Rotary India Pvt. Ltd., Chennai vs. DCIT, Chennai

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

ITA 2980/CHNY/2016[2006-07]Status: DisposedITAT Chennai12 Apr 2017AY 2006-07

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita No.2980/Mds/2016 "नधा"रण वष" / Assessment Year : 2006-07 M/S Rex Rotary India Pvt. Ltd., The Deputy Commissioner Of No.6, Shanmugam Street, V. Income Tax, Royapettah, Chennai - 600 014. Company Circle 5(3), Chennai - 600 034. Pan : Aabcr 3046 H (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri B. Ramakrishnan, FCAFor Respondent: Shri Durai Pandian, JCIT

Section 143(3)Section 147Section 148

revenue expenditure. The Ld. representative further submitted that the assessee has filed return of income for the year under consideration on 07.12.2006 and a revised return was also filed on the same day. The assessment order under Section 143(3) of the Act was passed on 08.12.2008. Subsequently, after expiry

DCIT Cir. 3(3)(2), Mumbai vs. Sundial Investments Pvt. Ltd., Mumbai

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

ITA 2345/MUM/2016[2011-12]Status: DisposedITAT Mumbai12 Apr 2017AY 2011-12

Bench: Sri Mahavir Singh, Jm & Sri Ramit Kochar, Am Dy. Commissioner Of Income Tax, Sundial Investments Pvt. Ltd. Room No. 609, 6Th Floor, 127, Jolly Maker Chambers Ii, Vs. Aayakar Bhavan, M.K. Road Nariman Point, Mumbai-20 Mumbai-400 021 .. Appellant Respondent Pan No. Aaacs9845C Revenue By .. Shri B Satyanarayana Raju, Dr Assessee By .. Shri Sunil Hirawat, Ar Date Of Hearing .. 12-04-2017 Date Of Pronouncement .. 12-04-2017

Section 143(3)Section 24

section 24(b) of the Act on account of genuineness of allowance of interest and also that the same was claimed by not filing revise return. For this Revenue has raised following two grounds: - “1. On the facts and in the circumstances of the case ... assessee u/s 24(b) of the Act without appreciating the fact that the revised claimed of interest was not made by filing any revised return of income but during the assessment proceeding which is in contravention to the decision of the Hon'ble Supreme Court in the case of Goetz

Deloitte Touche Tohmatsu India P.Ltd, Mumbai vs. CIT 1, Mumbai

ITA 1793/MUM/2015[2010-11]Status: DisposedITAT Mumbai12 Apr 2017AY 2010-11

For Appellant: Shri J.D. Mistri-ARFor Respondent: Shri Rahul Raman-DR

Section 143(3)Section 254(1)Section 263

declaring income of Rs.47.55 lakhs. Later on, a revised computation of income was filed on 30.03.2012,declaring income of Rs.3.89crores.In the revised return depreciation was claimed at Rs.58.11 lakhs as against Rs.3.80 crores,claimed in the original return.The AO completed the assessment u/s.143(3) of the Act on 28.03.2003. 2.After

DCIT 2(2), Mumbai vs. Kaytee Corporation P.Ld, Mumbai

In the result, this appeal filed by the revenue is Partly

ITA 2277/MUM/2013[2009-10]Status: DisposedITAT Mumbai12 Apr 2017AY 2009-10

Bench: Shri Shamim Yahya, Am & Shri Ravish Sood, Jm

For Appellant: Ms. Aarti VissanjiFor Respondent: Shri Rajesh Kumar Yadav

Section 14A

prior period expenses disallowed in A.Y.2007-08, ignoring that the assessee had not made a claim in its return for the A.Y.2006-07 nor filed a revised return of claim the said expenses, which is in contravention of the decision of the Hon’ble Supreme Court in the case of Goetz (India ... pertains to the A.Y. under question. 7.2 The AO did not consider the appellant’s claim stating that the appellant has not filed any revised return as required in the case of Goetz India (Ltd.) 284 ITR 323.” 11. Upon assessees appeal learned CIT(A) held that Assessing Officer