“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

Kamuthi Solar Power Limited (Merged With Adani Green Energy Twenty -Three Ltd.), Ahmedabad vs. The Pr. CIT, Ahmedabad-1, Ahmedabad

In the result, appeal of the assessee is allowed

ITA 1242/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad13 Feb 2026AY 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalkamuthi Solar Power Limited Vs. Principal Commissioner Of (Merged With Adani Green Income-Tax, Energy Twenty Three Ltd.), Ahmedabad-1 Adani House, Nr. Mithakhali Six Roads, Ahmedabad-380009 [Pan :Aafck 8399 E] (Appellant) .. (Respondent) Appellant By : Shri Biren Shah, Ar Respondent By: Shri R.P. Rastogi, Cit-Dr Date Of Hearing 10.12.2025 Date Of Pronouncement 13.02.2026

For Appellant: Shri Biren Shah, ARFor Respondent: Shri R.P. Rastogi, CIT-DR

Section 115BSection 143(3)Section 144BSection 263

assessment was completed under section 143(3) read with section 144B of the Act, assessing the total income at Nil, after considering the revised return and explanations furnished by the assessee during the assessment proceedings. 3.1 Thereafter, the Ld. PCIT issued a notice under section 263 of the Act proposing

Anil Bhagwan Turuk, Pune vs. ITO Ward 8(3), Pune

In the result, appeal of the assessee in ITA No

ITA 2585/PUN/2025[2020-21]Status: DisposedITAT Pune13 Feb 2026AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2584 & 2585/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Anil Bhagwan Turuk, V Income Tax Officer, 431/2329, Sant Tukaram S Ward-8(3), Pune. Nagar, Pimpri, Haveli, Pune – 411018. Pan: Aappt2146K Appellant/ Assessee Respondent /Revenue Assessee By Smt. Deepa Khare Revenue By Shri Ajitesh Kumar Meena – Addl.Cit Date Of Hearing 29/01/2026 Date Of Pronouncement 13/02/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2020-21 Dated 23.07.2025 & 28.08.2025 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 144B Of The Act, Dated 13.09.2022 & Penalty Order Under Section 270A Of The Act, Dated 22.03.2023 Respectively. For The Sake Of Convenience

Section 10Section 10(10)Section 143(3)Section 144BSection 250Section 270ASection 89(1)

assessee filed original return of income electronically for the A.Y.2020-21 on 31.10.2020 declaring total income of Rs.16,25,300/-. Thereafter, the assessee filed revised return of income electronically on 26.03.2021 declaring total income of Rs.4,47,310/-. Assessee’s Revised Return of Income was selected for scrutiny. During the assessment

Anil Bhagwan Turuk, Pune vs. ITO Ward 8(3), Pune

In the result, appeal of the assessee in ITA No

ITA 2584/PUN/2025[2020-21]Status: DisposedITAT Pune13 Feb 2026AY 2020-21

Section 10Section 10(10)Section 143(3)Section 144BSection 250Section 270ASection 89(1)

Inglorious Films LLP, Mumbai vs. Income Tax Officer, Mumbai

In the result, the Assessee’s appeal is allowed for statistical purposes

ITA 6624/MUM/2025[2020-21]Status: DisposedITAT Mumbai12 Feb 2026AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2020-21 Inglorious Films Llp, Income Tax Officer, Unit No.301, 3Rd Floor, Crescent Wrqh C23, Maharshi Karve Royale, Veera Desai Road, Off Rd., New Marine Lines, Vs. New Link Road, Oshiwara, Aayakar Bhawan, Andheri – West, Mumbai – Churchgate, Mumbai – 400053. 400020. Pan –Aaffi0742Q (Appellant) (Respondent) Present For: Assessee By : Mr. Aamod Prabhudesai, Ca Revenue By : Shri Virabhadra Mahajan, (Sr. D.R.) Date Of Hearing : 22.01.2026 Date Of Pronouncement : 12.02.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 20.08.2025, Impugned Herein, Passed By Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2020-21. 2. In The Instant Case, The Assessee Challenged The Rectification Order Dated 07.03.2023 Under Section 154 Of The Act By Filing First Appeal Before The Ld. Commissioner Claiming Deduction On Donation Of Rs.5,00,000/- Under Section 80(G) Of The Act. The Ld. Commissioner Dismissed The Said Appeal By Considering The Peculiar Facts & Circumstances, Specific To The Effect That The Assessee 2 Inglorious Films Llp Cannot Claim Any Deduction (Herein Deduction Under Section 80(G) Of The Act) At The Appellate Stage, When The Same Has Not Been Claimed In The Original Return Of Income, Without Revising Itr Within Stipulated Time & Therefore, He Is Constrained Not To Allow This Claim Of Deduction At This Stage.

For Appellant: Mr. Aamod Prabhudesai, CAFor Respondent: Shri Virabhadra Mahajan, (SR. D.R.)

Section 154Section 250Section 80

Bombay High Court) and claimed that the Assessee can make fresh claims before the appellate authorities, even otherwise by way of filing original or revised return of income. Fresh claims also include cases, where the ground though available, when the return was filed or the assessment order was made

Neysa Jewllery Ltd, Mumbai vs. DCIT, Cir-2(3)(1), Mumbai

In the result, the grounds of appeal raised by the assessee are allowed

ITA 5934/MUM/2025[2005-06]Status: DisposedITAT Mumbai12 Feb 2026AY 2005-06

Bench: Shri Pawan Singh& Shri Arun Khodpia(Physical Hearing)

Section 10ASection 133ASection 143(3)Section 254(1)Section 271(1)(c)

account of commission payable to Hitesh Trading Co., Singapore which was more compared to earlier year. The AO further recorded that the assessee filed revised return on 13.02.2006 declaring income of Rs. 6.67 crore after withdrawing the claim under section 10A and also offered ITA 5934/Mum/2025 (AY 2005-06) Neysa ... Jewellery Limited additional income on account of commission income of Rs. 1.90 crore. The revised return was further revised on 31.03.2007 declaring total income of Rs. 5.74 crore wherein loss on account of forward contract of Rs. 98,98,011/- considered as it was not disallowed in the computation

Zensar Technologies Limited, Mumbai vs. DCIT Circle 2(3)(1), Mumbai

In the result, appeal is allowed

ITA 3439/MUM/2025[2020-21]Status: DisposedITAT Mumbai12 Feb 2026AY 2020-21

Bench: Shri Saktijit Dey & Shri Arun Khodpia

Section 10ASection 115JSection 142(1)Section 263Section 80GSection 80J

under normal provisions of the Act and book profit of Rs.275,57,06,552/- u/s. 115JB of the Act. Subsequently, the assessee filed a revised return of income on 31.03.2021, declaring income of Rs.169,58,36,070/- under normal provisions and book profit at Rs.275,57,06,552/- u/s. 115JB ... were identified by the Assessing Officer for enquiry/examination:- i. Double Taxation Relief u/s. 90/91. ii. iii. iv. V. vi. vii. Reduction of Income in Revised Return & Claim of Refund. Imports. Loss from Currency Fluctuations. Refund Claim. ICDS Compliance and Adjustment. Expenses Incurred for Earning Exempt Income. viii. Deduction on Account

Firstrand Bank Limited, Mumbai vs. The Assistant Comm. of Income Tax-Circle-2(3)(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 2502/MUM/2022[2018-2019]Status: DisposedITAT Mumbai12 Feb 2026AY 2018-2019

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2018-19 Firstrand Bank Limited The Assistant Commissioner Of C-53, G-Block, 5 Th Floor, Income-Tax, Tcg Financial Centre, Circle-2(3)(1), Bandra-Kurla Complex, Mumbai Vs. Bandra (East)., Mumbai -400051 (Pan: Aabcf1632P) (Appellant) (Respondent) Present For: Assessee : Shri Paras Savla, Advocate Revenue : Shri Annavaram K, Sr. Dr Date Of Hearing : 14.11.2025 Date Of Pronouncement : 12.02.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Final Assessment Order Passed Pursuant To The Directions Of Ld. Dispute Resolution Panel- 1, Mumbai, Vide Order No. Itba/Drp/F/144C(5)/2022- 23/1043517868(1), Dated 22.06.2022, Passed U/S. 144C(5) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), For Assessment Year 2018-19. 2. Grounds Taken By The Assessee Are Reproduced As Under:

For Appellant: Shri Paras Savla, AdvocateFor Respondent: Shri Annavaram K, Sr. DR

Section 144C(5)Section 40Section 9(1)(vi)

Assessment Year 2018-19 on the ground that there was no provision in the Act permitting such adjustment otherwise than by filing a revised return of income. Ld. Assessing Officer relied upon the Supreme Court's decision in Goetze (India) Ltd. v. CIT 284 ITR 323 (SC) to hold that

Ferranza Electric Vehicle Private Limited, Faridabad vs. DCIT, Faridabad

In the result, appeal filed by the assessee is allowed

ITA 5454/DEL/2025[2023-24]Status: DisposedITAT Delhi12 Feb 2026AY 2023-24

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

For Appellant: Sh. Rahul Agarwal, Adv &For Respondent: Ms.Harpreet Kaur Hansra, Sr. DR

Section 115BSection 139(1)Section 139(5)Section 139(9)Section 143(1)Section 154

filed its return of income which was subsequently treated as invalid u/s 139(9) of the Act. Upon intimation assessee had filed the revised return u/s 139(5) of the Act on 18.12.2023. We observed that lower authorities have denied the concessional rate on the basis of not filing

Anil Tuteja, Fatehabad vs. Pr. Commissioner of Income Tax, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 780/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: BEFORE: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR