“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

Housing & Urban Development Corporation Ltd (Hudco), New Delhi vs. Addl. CIT, Range-4, New Delhi

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

ITA 7629/DEL/2018[2009-10]Status: DisposedITAT Delhi25 Apr 2025AY 2009-10

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR

Section 14ASection 36(1)(viia)

Accounts 4. The Ld. CIT (A) has erred in facts and in law by not deleting the addition made by Ld. Assessing Officer being Revised Return not considered. 5. The Learned CIT(A) has erred in fact and in law by not giving the benefit of Incremental Special Reserve ... ground no 4 is with respect to addition sustained by the CIT(A) where the AO did not consider the revised Return. The brief facts in this case are that a revised return was filed by the assessee on 27.10.2006 for the following reasons: Arranger fees

Housing & Urban Development Corporation Ltd (Hudco), New Delhi vs. Addl. CIT, Special Range-4, New Delhi

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

ITA 7628/DEL/2018[2008-09]Status: DisposedITAT Delhi25 Apr 2025AY 2008-09

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR

Section 14ASection 36(1)(viia)

Housing & Urban Development Corporation Ltd (Hudco), New Delhi vs. Addl. CIT, Range-4, New Delhi

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

ITA 7626/DEL/2018[2005-06]Status: DisposedITAT Delhi25 Apr 2025AY 2005-06

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR

Section 14ASection 36(1)(viia)

Cobol Technologies P.Ltd, New Delhi vs. ACIT, Central Circle-18, New Delhi

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 5505/DEL/2018[2014-15]Status: DisposedITAT Delhi25 Apr 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

maintained. The assessee had filed its return of income for AY 2009-10 declaring loss of Rs.205,53,32,506/-. The assessee filed revised return of income on 07.03.2010 declaring revised loss of Rs.391,45,89,643/-. Owing to complexity of the accounts, the Assessing Officer (AO) directed for Special

Sardarsarovar Narmada Nigam Ltd., Gandhinagar vs. The Pr. CIT, Ahmedabad-3, Ahmedabad

In the result, the appeal filed by the assessee stands dismissed

ITA 821/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad24 Apr 2025AY 2018-19

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.821/Ahd/2024 िनधा"रण वष" /Assessment Year : 2018-19 Sardarsarovar Narmada The Pr.Cit, बनाम/ Nigam Ltd. Ahmedabad-3 V/S. Block-12, 1St Floor Ahmedabad – 380 014 Near Sachivalaya Complex Gandhiangar -382 010 (Gujarat) "थायी लेखा सं./Pan: Aaccs 6704 L अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Ms. Arti N. Shah, Ar Revenue By : Shri Alpesh Parmar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 22/04/2025 घोषणा की तारीख /Date Of Pronouncement: 24/04/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Ms. Arti N. Shah, ARFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 143(3)Section 144BSection 263Section 37(1)

income for the Assessment Year 2018-19 on 13.10.2018 declaring a total loss of Rs.31,29,63,81,420/-. Subsequently, the assessee filed a revised return of income on 12.02.2019 declaring an enhanced loss of Rs.36,89,61,55,368/-. The case was selected for scrutiny under the Complete Scrutiny

Dy.Commissioner of Income Tax, Central Circle-1, Aurangabad vs. Siddhi Vinayak Construction, Aurangabad

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

ITA 988/PUN/2024[2020-21]Status: DisposedITAT Pune24 Apr 2025AY 2020-21

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21

For Appellant: Shri Shubham N RathiFor Respondent: Shri Ajay Kumar Keshari - CIT

Section 115JSection 139(1)Section 80I

appellate proceedings which were not made in the return of income filed. 10.7 In the present case, the appellant could not file the revised return as the time limit to file the same had expired and substantial compliance required for claiming the deduction u/s 80IB(10) has been duly complied ... 80IB(10) of the Act. He submitted that since the assessee never claimed the same in the return filed originally nor filed a revised return to claim the said deduction, therefore, it was beyond the power of the Ld. CIT(A) to discuss and decide the issue

Srk Constructions and Projects Private Limited, Hyderabad vs. DCIT, Circle-3(1), Hyderabad

In the result, ITA.No.389/Hyd

ITA 359/HYD/2022[2016-17]Status: DisposedITAT Hyderabad24 Apr 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: Shri LV Bhaskara Reddy, CIT-DR

Section 139(1)Section 143(3)Section 263

income of Rs.28,06,85,620/- under normal provisions of the Income Tax Act, 1961 [in short “the Act”]. The assessee filed it’s revised return of income on 23.08.2017 and admitted income of Rs.7,00,46,470/- after claiming deduction u/sec.80IA of Rs.21.06,39,150/- towards profit derived from

Dy. Commissioner of Income Tax, Circle-3(2), Hyderabad vs. Srk Construction Projects Private Limited, Hyderabad

In the result, ITA.No.389/Hyd

ITA 1415/HYD/2019[2016-17]Status: DisposedITAT Hyderabad24 Apr 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: Shri LV Bhaskara Reddy, CIT-DR

Section 139(1)Section 143(3)Section 263

Madhu Reansport Company Private Limited., Kolkata vs. ITO, Ward-II(1), Kolkata.

In the result, the appeal is allowed

ITA 1233/KOL/2024[2008-09]Status: DisposedITAT Kolkata24 Apr 2025AY 2008-09

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri G.P. Shukla, ARFor Respondent: Shri Subhro Das, DR

Section 201Section 40

assessee qua the profit from the infrastructure facilities. The AO observed that the assessee has also not made its claim by filing a revised return of income and therefore, the same is not allowable to the assessee. 010. In the appellate proceedings, the Id. CIT (A) also rejected the claim

The Pr Commissioner of Income Tax IV New Delhi vs. Ntpc Vidyut Vyapar Nigam Ltd

ITA/260/2024HC Delhi23 Apr 2025

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA

For Appellant: Mr Shlok Chandra, senior standing counselFor Respondent: Mr Ved Jain and Mr Nischay Kantoor

Section 143(3)Section 263

business of trading energy. During the relevant year, it was also engaged in trading fly ash and related products. 4. The Assessee filed its revised return of income for the financial year [FY] relevant to AY 2015-16 on 15.06.2016, declaring a profit of ₹98,84,52,500/-. The Assessee

Jitender Singh, Haridwar vs. DCIT, Circle- Haridwar, Haridwar

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

ITA 29/DDN/2024[2013-14]Status: DisposedITAT Dehradun23 Apr 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Shri Jitender Singh, Vs. Dcit, Village-Jagjeetpur, Po Circle, Kanghal, Haridwar Haridwar (Appellant) (Respondent) Pan: Ahaps4448R

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri A. S. Rana, Sr. DR

Section 133ASection 142ASection 143(3)Section 254Section 69

survey u/s 133A of the Act of the Act was conducted after which the assessee filed revised return on 24.02.2014 showing total income of Rs. 1,47,94,720/-. The ld AO observed during the year the assessee was running a hospital called Jan Jeevan Hospital wherein, he had declared ... assessee surrendered a sum of Rs. 70,60,117/- and offered a Shri Jitender Singh sum towards investment in hospital building in the revised return filed on 24.02.2014. Further, the assessee even justified with supporting bills, vouchers and documentary evidence as to how the surrendered made

Sh. Aroon Kumar Sinha, Dehradun vs. ITO, Ward-1(1), Dehradun

Appeal is allowed for statistical purposes

ITA 13/DDN/2024[2015-16]Status: DisposedITAT Dehradun23 Apr 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Assessment Year: 2015-16 Sh. Aroon Kumar Sinha, Vs. Income Tax Officer, 1, Army Office Enclave, Ward-1(1), Laxmipur Po, Umedpur, Dehradun Dehradun, Uttarakhand Pan :Aidps7458R (Appellant) (Respondent) Assessee By None Department By Sh. A.S. Rana, Sr. Dr Date Of Hearing 17.03.2025 Date Of Pronouncement 23.04.2025 Order

Section 144Section 54Section 54F

thereafter, rejected his claim of section 54 deduction (originally raised) and latter on sought under section 54F of the Act; for want of a revised return, in light of Goetze India Ltd. Vs. CIT, (2006) 284 ITR 323 (SC), in the course of assessment framed on 28.12.2017 and upheld ... section 144 best assessment on 28.12.2017 rejecting the assessee’s section 54F deduction claim, earlier sought under section 54F for not filing a revised return. 2 | P a g e 6. Coming to the CIT(A)/NFAC lower appellate discussion, we note from a perusal of para 5.2 onwards

Deputy Commissioner of Income Tax, Circle-Imphal, Imphal vs. Shri Laishram Mani Singh, Imphal

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

ITA 31/GTY/2021[2014-15]Status: DisposedITAT Guwahati23 Apr 2025AY 2014-15

Bench: The Ld. Ao. It Is Seen That The Ld. Cit(A) Had Access To More

Section 132Section 144Section 250Section 271(1)(c)Section 271A

members Assessee initially declared certain loss for relevant year but when Assessing Officer, confronted assessee with audited financial statements for concerned period assessee revised return and declared certain profit Assessing Officer therefore, imposed penalty under section 271(1)(c) on assessee for concealing particular of its income and for furnishing

Shilpa Tanuj Pugalia, Ahmedabad vs. The Pr. CIT, Central, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 741/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad23 Apr 2025AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri Tushar Hemani, Sr. AdvocateFor Respondent: Shri R.N. Dsouza, CIT(DR)

Section 147Section 148Section 263

case was reopened u/s. 147 of the Act. Pursuant to reopening under section 147 of the Act, the assessee filed a revised return on 16.08.2021 declaring Rs. 63,21,450/-, and the assessment was completed on 18.03.2022 accepting the returned income. 4. The Ld. PCIT noted that based

Mmtc Ltd vs. DCIT Circle 5(1)

In the result the appeal of the assessee is allowed

ITA 2732/DEL/2006[2004-2005]Status: DisposedITAT Delhi23 Apr 2025AY 2004-2005

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.Clix Capital Services Pvt. Ltd, Vs. Pcit, Plot No. 23, 5Th Floor, Aggarwal Delhi-1, Delhi Corporate Tower Govind Lal Sikka Marg, Rajendra Place, West Delhi, New Delhi, Delhi, India, 110008 (Appellant) (Respondent) Pan: Aaacc0642F

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Sanjay Kumar Bharati, CIT DR

Section 139(1)Section 143(3)Section 144BSection 263Section 37

NBFC) and had filed its original return of income u/s 139(1) of the Act for AY 2018-19 on 29.09.2018. It had filed revised return on 29.03.2019 declaring loss of Rs. 10,68,63,896/-. The case of the assessee was selected for complete scrutiny to examine the following

Veetraag Vani Trust Regsd, Tikamgarh vs. ITO, Exemption Ward, Gwalior

The appeal stand dismissed

ITA 31/AGR/2023[ 2014-15]Status: DisposedITAT Agra22 Apr 2025

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.31/Agr/2023 (िनधा"रणवष" / Assessment Year: 2014-15) Veetraag Vani Trust Income-Tax Officer (Exemption) बनाम/ Sahil Sagar Chauraha Ward- Gwalior. Near Arihant Public School, Vs. Tikamgarh (Mp). "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-6832-H (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Rajendra Sharma, Adv. – Ld. Ar " थ"कीओरसे/Respondent By : Sh. Shailender Shrivastava – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 18-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 22.04.2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2014-15 Arises Out Of An Order Passed By Of Learned Commissioner Of Income Tax (Appeals), Nfac, Delhi [Cit(A)] On 28-12-2022 In The Matter Of An Rectification Order Passed By Ld. Ao U/S 154 On 18-12-2020. It Emerges That The Assessee Filed Return Of Income At Rs.20.79 Lacs Which Was Accepted U/S 143(1). The Assessee Revised Return Of Income On 28-02- 2016 Claiming Exemption U/S 10(23)(Iiiad) Followed By Rectification Which Was Rejected On The Ground That There Was No Mistake Apparent From Record. The Rectification Order Was Under Challenge Before Ld. Cit(A). In Para 9.7 Of Impugned Order, Ld. Cit(A) Confirmed The Rectification Order On The Ground That The Fresh Claim So Made By The Assessee Was Beyond

For Appellant: Sh. Rajendra Sharma, Adv. – Ld. ARFor Respondent: Sh. Shailender Shrivastava – Ld. Sr. DR

Section 10(23)(iiiad)Section 143(1)Section 154

emerges that the assessee filed return of income at Rs.20.79 Lacs which was accepted u/s 143(1). The assessee revised return of income on 28-02- 2016 claiming exemption u/s 10(23)(iiiad) followed by rectification which was rejected on the ground that there was no mistake apparent from record

Superfine Hotels Private Limited, Jaipur vs. Deputy Commissioner of Income Tax, Circle-6, Jaipur

In the result, appeal of the assessee is partly allowed

ITA 1502/JPR/2024[2015-16]Status: DisposedITAT Jaipur22 Apr 2025AY 2015-16

For Appellant: Shri S.L. Poddar, Adv. &For Respondent: Shri P.P. Meena, CIT

Section 250Section 271(1)(c)Section 35A

records that claims made by assessee were based on experts advice and backed by certification issued in Form 10CCB—It was also noted that revised return so filed was also valid return filed within stipulated time-High Court in case of Chander Pal Bagga &Harshvardhan Chemicals Ltd held that ... claims made by the assessee were based on experts advice and backed by certification issued in Form 10CCB. It is also noted that the revised return so filed was also a valid return filed within the stipulated time. The ld. AR relied on the decision of Jurisdictional High Court

DCIT, Range-3, Lucknow vs. M/S Welldone Infrastructure Pvt. Ltd., Lucknow

In the result, the appeal of the Revenue is dismissed

ITA 406/LKW/2020[2017-18]Status: DisposedITAT Lucknow22 Apr 2025AY 2017-18

Bench: Sh.Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y.2017-18 Dy. Commissioner Of Income Tax, Vs. M/S Welldone Infrastructure Range-3, Lucknow Private Limited, Lucknow Pan:Aaacw6354Q (Appellant) (Respondent) Assessee By: Sh. B.P. Yadav, Advocate Revenue By: Sh. Amit Singh Chauhan, Addl (Cit) & Sh. Sunil Kumar Rajwanshi, Addl Cit (Dr) Date Of Hearing: 10.02.2025 Date Of Pronouncement: 22.04.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Revenue Against The Order Of The Ld. Cit(A)-2, Lucknow Under Section 250 Of The Income Tax Act, 1961 Allowing The Appeal Of The Assessee Against The Order Passed By The Ld. Ao Under Section 143(3) On 19.12.2019. The Grounds Of Appeal Are As Under:- “1. That The Ld. Cit(A)-2, Lucknow Has Erred In Law & On Facts In Deleting The Addition Of Rs.2,26,72,571/- Without Appreciate The Fact That The Assessee Is Involved In The Business Of Developing Properties & Selling It & Is Earning Rental Income Which Is Incidental To The "Revenue From Business Operations" Of The Assessee. 2. Ld. Cit(A) Had Erred In Law & On Facts Ignoring The Fact That The Assessee, While Filing Original Return Of Income Had Itself Considered That Rental Are In The Nature Of Revenue From Business Operations.

For Appellant: Sh. B.P. Yadav, AdvocateFor Respondent: Sh. Amit Singh Chauhan, Addl (CIT) & Sh

Section 143(3)Section 22Section 250

income to Nil. In the return initially filed, the assessee had shown all its receipts, as revenue from business and profession” whereas in the revised return, the assessee had recomputed its profits by showing rental receipts under the head, “income from house property”. The assessee was asked to explain ... property. It was further submitted that the assessee had taken a loan under the Rental Securitization Scheme and therefore, it had justifiably filed the revised return showing rental income as assessable under, “income from house property”. The ld. AO was not convinced with the explanation submitted by the assessee

C G Marketing Pvt Ltd, Pune vs. DCIT, Circle 1(1), Pune

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

ITA 134/PUN/2025[2020-21]Status: DisposedITAT Pune22 Apr 2025AY 2020-21

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2020-21

For Appellant: Shri Sarvesh KhandelwalFor Respondent: Shri Ramnath P Murkunde

Section 143(2)Section 143(3)Section 254Section 80G

otherwise, even if the assessee had inadvertently not claimed the deduction u/s 80G in the return, he could have claimed it by filing a revised return. In view of the foregoing, the said claim of the appellant is rejected. All the grounds of appeal are deemed to have been dismissed ... which the Ld. CIT(A) / NFAC has rejected on the ground that the assessee had not claimed the same by filing the revised return. We find the Hon'ble Supreme Court in the case of Goetze India Ltd. vs. CIT (2006) 284 ITR 323 (SC) has held that the said

The Shiv Shakti Educational Society, Sonepat vs. ITO Exemption, Rohtak

The appeal is allowed for statistical purposes

ITA 1050/DEL/2024[2014-15]Status: DisposedITAT Delhi22 Apr 2025AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2014-15 The Shiv Shakti Educational Vs Ito, Society, Exemption, Mehlana Road, Rohtak. Sonepat, Haryana – 131 001. Pan: Aadat7095C (Appellant) (Respondent) Assessee By : Shri Priyanshu Singhal, Ca & Ms Mansi Jain, Ca Revenue By : Shri Amit Katoch, Sr. Dr Date Of Hearing : 22.04.2025 Date Of Pronouncement : 22.04.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Order Dated 19.01.2024 Of The Commissioner Of Income-Tax (Appeals), Visakhapatnam (Hereinafter Referred To As ‘The Ld. Faa’, For Short), In Appeal No.Nfac/2013- 14/10223639 Arising Out Of The Appeal Before It Against The Order Dated 16.03.2016 Passed U/S 143(1) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By The Dcit, Centralized Processing Centre, Bengaluru (Hereinafter Referred To As The Ld. Ao).

For Appellant: Shri Priyanshu Singhal, CA &For Respondent: Shri Amit Katoch, Sr. DR

Section 10Section 143(1)Section 154

that the assessee was diligently contesting the issue by way of filing a rectification application. 3. We find that the assessee had filed a revised return of income and an application u/s 154 of the Act before the competent authority. The appellant society is an educational society having gross receipt ... claimed by the assessee. It was submitted before the ld.CIT(A) that under the bona fide belief the assessee has filed revised return and has also filed a rectification application for deleting the demand, the appeal was not preferred. Admittedly, as per the order of the ld.CIT(A), the rectification