“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

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

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

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

Herbalife International India Pvt Ltd vs. The Commissioner of Income Tax

In the result, the assessee's appeal for

ITA/433/2018HC Karnataka20 May 2025

Bench: V KAMESWAR RAO,S RACHAIAH

Section 143(3)Section 144CSection 260Section 263

income on 13.09.2008 declaring a total loss of Rs.3,03,76,816/-. The said return was subsequently revised and the appellant filed a revised return on 31.03.2010 declaring a total loss of Rs.3,67,17,524/-. According to the appellant, during - 4 - ITA No. 433 of 2018 the impugned Assessment ... prescribed under Rule-5 of Income Tax Rules, 1962, the appellant claimed 100% depreciation on the aforesaid additions for the impugned Assessment Year. A revised return filed on 31.03.2010 was taken-up for scrutiny by the Assessing Officer, which was concluded by the order dated 29.10.2012 passed under Section

Shree Jamkandorna Taluka Co-Op. Sales and Purchase Union Ltd., Janmkandorana, Rajkot vs. Income Tax Office, Ward 2(1)(2), Rajkot

The appeal is allowed for the statical purpose

ITA 58/RJT/2024[2018-19]Status: DisposedITAT Rajkot20 May 2025AY 2018-19

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.58/Rjt/2024 "नधा"रणवष" / Assessment Year: (2018-19) (Hybrid Hearing) Shree Jamkandorna Taluka Co-Op. Vs. Income Tax Officer, Sales & Purchase Union Ltd Ward2(1)(2), C/O. Sarda & Sarda, Cas, Rajkot. 1St Floor, “Sakar”, Dr. Radhakrishnan Road, Opp. Rajkumar College, Rajkot-360001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaas2296M (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav , Ld. Sr. (Dr) Date Of Hearing : 25/02/2025 Date Of Pronouncement : 20/05/2025 आदेश / O R D E R

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav , Ld. Sr. (DR)

Section 139(5)Section 143(1)Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(2)(f)

which was revised u/s 139(5) of the Act on 16/02/2019 wherein total income of the appellant remined same. The said revised return of income was processed u/s 143(1) of the act on 12/07/2019 determining total income at 13,52,008/-. In the said intimation the CPC, Bangalore

M/S G.D. Tambi & Sons, Jaipur vs. ACIT, Circle-3, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 177/JPR/2025[2016-17]Status: DisposedITAT Jaipur20 May 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT-DR

Section 143(3)Section 24

light of Goetze (India) Pvt. Ltd. vs. CIT where honourable Supreme Court stated that any claim for deduction other than by filing a revised return is not acceptable. So the question of allowing deduction of interest u/s 24(b) does not stand. Further, the assessee has failed to establish that ... Supreme Court Goetze India Pvt Ltd vs CIT where it was held that claim for deduction other than by filing a revised return is not acceptable. Further assessee has failed to establish that the borrowed funds on which interest was paid were used for the purchase of let out properties

M/S G.D. Tambi & Sons, Jaipur vs. ACIT, Circle-3, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 176/JPR/2025[2015-16]Status: DisposedITAT Jaipur20 May 2025AY 2015-16

Bench: moving towards the facts of the case we would like to mention that the assessee has assailed the appeal for assessment year 2015-16 in

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT-DR

Section 143(3)Section 24

Aksh Optifibre Limited, New Delhi vs. ACIT, Circle - 2, Alwar

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

ITA 170/JPR/2024[2010-11]Status: DisposedITAT Jaipur20 May 2025AY 2010-11

For Appellant: Shri Akul Agarwal, C.A. (thr. V.C.)For Respondent: Shri Arvind Kumar, CIT-DR

Section 143(3)Section 147Section 148Section 156Section 234ASection 250

MIPL. 3. The original return of income was not revised even though the assessment proceedings were pending. The last date for filing the revised returns was 31.03.2008, after the amalgamation order. 4. A search and seizure proceeding was conducted in respect of the Mahagun group, including the MRPL and other ... following bases. 1. The original return of income was not revised even though the assessment proceedings were pending. The last date for filing the revised returns was 31/03/2008, after the amalgamation order. 2. When search and seizure of the Mahagun group took place, no indication was given about the amalgamation

Vardhman Special Steels Ltd., Ludhiana vs. DCIT, Circle-1, Ludhiana

ITA 79/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh20 May 2025AY 2018-19

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 115JSection 142(1)Section 143(2)Section 14ASection 270ASection 36(1)Section 36(1)(iii)Section 57

09/10/2018, declaring a total income of "Nil," a long-term capital loss of Rs.29,69,207/-, and exempt income of Rs.1,41,656/-. A revised return was filed on 30/03/ 2019, maintaining the total income as "Nil," with a reduced long-term capital loss ... month and also started penalty proceedings under Section 270A.The AO added this disallowance, along with Rs. 1,78,314/-under Section 14A, to the revised returned income of Rs.14,69,49,564/-, resulting in a total income of Rs.14,79,43,888/-. However, after setting off earlier year losses

Indian Coal Agency, Kolkata vs. DCIT, Circle-35, Kolkata

In the result, the appeal for AY 2013-14 is partly allowed

ITA 868/KOL/2018[2015-16]Status: DisposedITAT Kolkata20 May 2025AY 2015-16

Bench: Sonjoy Sarma & Sri Rakesh Mishra

Section 143(3)Section 14A

return of income for AY 2013-14 on 16.09.2013 declaring total income of Rs. 27,87,02,400/-. Later on, the assessee filed a revised return showing total income of Rs. 25,99,91,840/-. The case was selected for scrutiny through CASS and statutory notices ... erroneous and prejudicial to the interests of the Revenue. He therefore, set aside the order and directed the Ld. AO to take the revised return on account for computation of total income, recompute the disallowance as per Rule 8D of the Income Tax Rules, 1962 and examine the correctness

Indian Coal Agency, Kolkata vs. Principal CIT, Circle - 12, Kolkata

In the result, the appeal for AY 2013-14 is partly allowed

ITA 867/KOL/2018[2013-14]Status: DisposedITAT Kolkata20 May 2025AY 2013-14

Bench: Sonjoy Sarma & Sri Rakesh Mishra

Section 143(3)Section 14A

DCIT, Circle-35, Kolkata vs. M/S. Indian Coal Agency, Kolkata

In the result, the appeal for AY 2013-14 is partly allowed

ITA 1258/KOL/2018[2015-16]Status: DisposedITAT Kolkata20 May 2025AY 2015-16

Bench: Sonjoy Sarma & Sri Rakesh Mishra

Section 143(3)Section 14A

Shri Chhatrapati Sskltd, Pune vs. DCIT Circle-14, Pune

In the result, the appeal filed by the assessee in ITA

ITA 1924/PUN/2024[2009-10]Status: DisposedITAT Pune19 May 2025AY 2009-10

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1923 & 1924/Pun/2024 िनधा"रण वष" / Assessment Years : 2008-09 & 2009-10 Shri Chhatrapati Sahakari Vs. Dcit, Circle-14, Pune. Sakhar Karkhana Ltd., A/P. Bhavaninagar, Tal. Indapur, Dist. Pune- 413104. Pan : Aaaas3869G Appellant Respondent Assessee By : Shri Hanmant D. Dhavale Revenue By : Shri Ramnath P. Murkunde Date Of Hearing : 20.02.2025 Date Of Pronouncement : 19.05.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 07.08.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2008-09 & 2009-10 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1923/Pun/2024 For Assessment Year 2008-09 As A Lead Case For Adjudication.

For Appellant: Shri Hanmant D. DhavaleFor Respondent: Shri Ramnath P. Murkunde

Section 143(3)Section 154Section 155(19)

engaged in the business of manufacturing of sugar and crushing of can and has furnished its original return of income on 26.09.2008 and revised return of income on 28.09.2009 declaring total income of Rs.Nil. The assessment was completed u/s 143(3) of the IT Act on 24.12.2010 by determining total

Shri Chhatrapati Sskltd., Pune vs. DCIT Circle -14, Pune

In the result, the appeal filed by the assessee in ITA

ITA 1923/PUN/2024[2008-09]Status: DisposedITAT Pune19 May 2025AY 2008-09

For Appellant: Shri Hanmant D. DhavaleFor Respondent: Shri Ramnath P. Murkunde

Section 143(3)Section 154Section 155(19)

Venkateshwar Reddy Atigadda, Hyderabad vs. ACIT., Circle-8(1), Hyderabad

In the result, appeals filed by the assessee for both the assessment years 2013-14 and 2016-17 are allowed

ITA 1286/HYD/2024[2016-2017]Status: DisposedITAT Hyderabad16 May 2025AY 2016-2017

Bench: Shri Vijay Pal Rao (Vice President), Shri Manjunatha G. (Accountant Member)

For Appellant: Shri K.C.Devdas, ARFor Respondent: Shri Srinath Sadanala, DR

Section 139Section 147Section 148Section 271(1)(c)

Ld.CIT(A) in the impugned order has stated in para 6.3 as under : 10. Thus, the observation of the Ld.CIT(A) that the revised return was filed in response to the notice u/s 148, declaring the expenses not reported earlier is contrary to facts and record available with the department

Venkateshwar Reddy Attigada, Hyderabad vs. ACIT., Circle-8(1), Hyderabad

In the result, appeals filed by the assessee for both the assessment years 2013-14 and 2016-17 are allowed

ITA 1285/HYD/2024[2013-2014]Status: DisposedITAT Hyderabad16 May 2025AY 2013-2014

Bench: Shri Vijay Pal Rao (Vice President), Shri Manjunatha G. (Accountant Member)

For Appellant: Shri K.C.Devdas, ARFor Respondent: Shri Srinath Sadanala, DR

Section 139Section 147Section 148Section 271(1)(c)

Precision Hydraulics Private Limited, Thiruvallur vs. The Deputy Commissioner of Income-Tax, Corporate Circle 5(2), Chennai

In the result, appeal of the assessee is partly allowed

ITA 506/CHNY/2025[2016-17]Status: DisposedITAT Chennai16 May 2025AY 2016-17

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.506/Chny/2025 Assessment Years: 2016-17 Precision Hydraulics Private Limited, The Deputy Commissionner Of No.83,84 & 117, Income Tax, Sipcot Industrial Complex, Corporate Circle-5(2) Export Promotion Industrial Park, Chennai. Gummidipoondi, Tiruvallur Dist, Tamil Nadu-601201. [Pan: Aadcp7054M] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Shri Sandeep Pincha, C.A, प्रत्यर्थी की ओर से /Revenue By : Shri N.Rajakumar, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 13.05.2025 घोषणा की तारीख /Date Of Pronouncement : 16.05.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Shri Sandeep Pincha, C.AFor Respondent: Shri N.Rajakumar, Addl.CIT

Section 68

next issue raised by the appellant through the ground of appeal No.2 is regarding non-consideration of the figures given in its revised returns by the Ld.AO. Short brief factual matrix of the cases is that the assessee had filed to two revised returns after filing the original return ... income. The Ld. Council for the appellant has submitted that the Ld.AO took the income figures of the first revised return amounting to ₹2,34,73,190 as against the figure of ₹2,10,39,830 filed in the second revised return. In support of its contentions, the Ld.AR

Sreenivasulu Sagaleti, Bengaluru vs. Income Tax Officer, Ward-2(2)(2), Bengaluru

In the result, appeal filed by the assessee is allowed

ITA 2493/BANG/2024[2018-19]Status: DisposedITAT Bangalore16 May 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahuandshri.Keshav Dubeyassessment Year :2018-19

For Appellant: Shri. Sandeep Chalapathy, CAFor Respondent: Shri. Ganesh R Gale, Standing Counsel for Department

Section 139Section 139(1)Section 54FSection 54F(1)Section 54F(4)

assessee has claimed exemption U/s 54F of Rs 3,47,29,250 which was subsequently revised at Rs 3,42,31,397 in the revised return of income filed on 28.12.2010. Therefore, at the time of filing of the return of income, the entire compensation amounting

Ketan Harshadrai Mehta, Mumbai vs. Income Tax Officer Ward, 1(2)(5), Kalyan

In the result, the appeal of assessee is allowed

ITA 5449/MUM/2024[2017-18]Status: DisposedITAT Mumbai16 May 2025AY 2017-18

Bench: Shri Pawan Singh&Girish Agrawal(Physical Hearing) Ketanharshadrai Mehta Ito,Ward-1(2)(5), 67/2, Baliramganpatmahatre Bldg. Vs Kalyanmohan Plaza, Kongaon, Bhiwandi, Wayale Nagar, Khadakpada, Maharashtra-421311. Kalyan(W). [Pan No. Aajpm 9528 L Appellant / Assessee Respondent / Revenue

Section 254(1)Section 68

credited just before the transfer of fund to assessee. The bank statement was operated mainly for providing unsecured loans. The assessee provided copy of revised return of income of lender showing return income of Rs. 4.00 lack, which is not in commensurate with unsecured loans. The assessing officer

M/S Essar Shipping Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle 5(1)(1), Mumbai

In the result, ground no. 5 raised by the assessee is dismissed

ITA 4440/MUM/2024[2020-21]Status: DisposedITAT Mumbai16 May 2025AY 2020-21

Bench: Ms. Kavitha Rajagopal, Jm & Shri Omkareshwar Chidara, Am

For Respondent: Shri. Piyush Chaturvedi

Section 143(2)Section 144Section 144C(1)Section 41Section 92B(2)Section 92C

through its subsidiaries. The assessee had filed its return of income dated 29.09.2021 declaring total income at Rs.4,58,480/- and subsequently filed its revised return of income dated 18.11.2021, declaring total income at Rs.4,58,480/-. The assessee's case was selected for complete scrutiny on the following issues

G4S Secure Solutions (India) Private Limited, West Delhi, India vs. Central Processing Center, Bangalore

In the result, the appeal of the assessee is allowed

ITA 5285/DEL/2024[2023-24]Status: DisposedITAT Delhi16 May 2025AY 2023-24

Bench: Shri Shamim Yahya & Shri Vimal Kumarassessment Year: 2023-24 G4S Secure Solutions (India) Vs Cpc, Private Limited, Bengaluru. 9Th Floor, Tower-B, Good Earth Trade Tower, Sector-62, Bhondsi So (168), Gurugram, Haryana – 122 102. Pan: Aaacg1625Q (Appellant) (Respondent) Assessee By : Shri Salil Kapoor, Ms Ananya Kapoor & Shri Shivam Yadav, Advocates Revenue By : Shri Surender Pal, Cit, Dr Date Of Hearing : 12.03.2025 Date Of Pronouncement : 16.05.2025 Order Per Vimal Kumar, Jm: The Appeal By The Appellant/Assessee Is Against The Order Dated 23.09.2024 Of The Ld. Commissioner Of Income-Tax (Appeals)-6, Mumbai [Hereinafter Referred To As ‘The Ld. Cit(A)’] U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) In Appeal Arising Out Of The Order Dated 27.03.2024 U/S 143(1) Of The Act Of The Cpc, Bengaluru (Hereinafter Referred To As ‘The Ld. Ao’), For Assessment Year 2023-24. 2. Brief Facts Of The Case Are That The Assessee Filed The Original Return Of Income Along With Form 10Da On 29.11.2023. Subsequently, The Return Of Income Along With Form 10Da Was Revised On 30.12.2023. The Cpc Processed The Return Disallowing Deduction U/S 80Jjaa Of The Act, Vide Intimation Dated 27.03.2024. Against This Intimation Dated 27.03.2024, The Appellant Assessee Filed Appeal Before The Ld.Cit(A) Which Was Partly Allowed, Vide Order Dated 23.09.2024. 3. Being Aggrieved, The Appellant-Assessee Has Preferred The Present Appeal.

For Appellant: Shri Salil Kapoor, Ms Ananya KapoorFor Respondent: Shri Surender Pal, CIT, DR

Section 143(1)Section 250Section 80J

intimation was issued u/s. 143(1) and, therefore, the assessee had no opportunity to make a fresh claim by way of filing a revised return before the CPC, Bangalore since the process is Captain Steel India Ltd., AY 2019-20 completed. The claim made by the assessee at the first

Hari Om Rastogi, Fatehpur vs. ACIT (Central Circle), Allahabad

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 22/ALLD/2025[2019-20]Status: DisposedITAT Allahabad14 May 2025AY 2019-20

Bench: Shri Subhash Malguria & Shri Sanjay Awasthi

Section 132Section 139Section 139(1)Section 139(5)Section 142(1)Section 144Section 153ASection 69

assessee filed return of income u/s 139 of the Act on 31/10/2019 declaring total income of Rs.1,74,980/-. The assessee submitted a revised return on 01/02/2020 declaring total income of Rs.8,61,960/-. The Assessing Officer completed the assessment and assessed the total income of the assessee at Rs.44

Hari Om Rastogi, Fatehpur vs. ACIT (Central Circle) Allahabad, Allahabad

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 21/ALLD/2025[2018]Status: DisposedITAT Allahabad14 May 2025

Bench: Shri Subhash Malguria & Shri Sanjay Awasthi

Section 132Section 139Section 139(1)Section 139(5)Section 142(1)Section 144Section 153ASection 69