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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.

Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal
241 ITR 124 · 2000 · High Court
89
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
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.

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

ACIT, Circle- 26(2), New Delhi vs. Vodafone Idea Ltd. (Earlier Knwon As Vodafone Mobile Services Ltd.), New Delhi

ITA 8079/DEL/2018[2007-08]Status: DisposedITAT Delhi21 Mar 2025AY 2007-08

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 1999-2000 Vs. M/S. Vodafone West Ltd. Acit, Circle-26(2), (Thereafter Merged With New Delhi Vodafone Mobile Services Ltd.), C-48, Okhla Industrial Area, Phase-2, New Delhi Pan: Aaacf1190P (Appellant) (Respondent) With Assessment Year: 2007-08 Vs. M/S. Vodafone Idea Ltd. Acit, Circle-26(2), (Earlier Known As Vodafone New Delhi Mobile Services Ltd.), C-48, Okhla Industrial Area, Phase-2, New Delhi Pan: Aaacb2100P (Appellant) (Respondent) Assessee By Sh. Salil Kapoor, Adv. Sh. Anil Chachra, Adv. Ms. Ananya Kapoor, Adv. Department By Sh. Vijay B. Basanta, Cit(Dr) Date Of Hearing 06.03.2025 Date Of Pronouncement 21.03.2025 Order Per Satbeer Singh Godara, Jm These Revenue’S Appeals Ita No.7658/Del/2018 & 8079/Del/2018 For Assessment Years 1999-2000 & 2007-08

Section 271(1)(c)

actually incurred the expenditure, but the expenditures were disallowed because of difference of opinion between the assessee and the Assessing Officer. The revised return was filed because some of the expenditures were disallowed by the Commissioner (Appeals) for year 1998-89, although the expenditures were not doubted. There are cases ... between the assessee and the Assessing Officer, it cannot be said that the assessee has intention to conceal the income. The filing of the revised return, excluding some of the disallowed expenditure and claiming expenditure of INR 2 crores which was actually spent by the assessee in the relevant assessment

ACIT, Circle-26(2), New Delhi vs. Vodafone West Ltd., (Thereafter Merged With Vodafone Mobile Services Ltd.), New Delhi

ITA 7658/DEL/2018[1999-2000]Status: DisposedITAT Delhi21 Mar 2025AY 1999-2000

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 1999-2000 Vs. M/S. Vodafone West Ltd. Acit, Circle-26(2), (Thereafter Merged With New Delhi Vodafone Mobile Services Ltd.), C-48, Okhla Industrial Area, Phase-2, New Delhi Pan: Aaacf1190P (Appellant) (Respondent) With Assessment Year: 2007-08 Vs. M/S. Vodafone Idea Ltd. Acit, Circle-26(2), (Earlier Known As Vodafone New Delhi Mobile Services Ltd.), C-48, Okhla Industrial Area, Phase-2, New Delhi Pan: Aaacb2100P (Appellant) (Respondent) Assessee By Sh. Salil Kapoor, Adv. Sh. Anil Chachra, Adv. Ms. Ananya Kapoor, Adv. Department By Sh. Vijay B. Basanta, Cit(Dr) Date Of Hearing 06.03.2025 Date Of Pronouncement 21.03.2025 Order Per Satbeer Singh Godara, Jm These Revenue’S Appeals Ita No.7658/Del/2018 & 8079/Del/2018 For Assessment Years 1999-2000 & 2007-08

Section 271(1)(c)

actually incurred the expenditure, but the expenditures were disallowed because of difference of opinion between the assessee and the Assessing Officer. The revised return was filed because some of the expenditures were disallowed by the Commissioner (Appeals) for year 1998-89, although the expenditures were not doubted. There are cases ... between the assessee and the Assessing Officer, it cannot be said that the assessee has intention to conceal the income. The filing of the revised return, excluding some of the disallowed expenditure and claiming expenditure of INR 2 crores which was actually spent by the assessee in the relevant assessment

Mrs. Balu Sugunalatha, Chennai vs. ITO, Ncw-1(6), Chennai

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

ITA 263/CHNY/2025[2012-13]Status: DisposedITAT Chennai21 Mar 2025AY 2012-13

Bench: Shri George George K., Vice- & Shri S.R. Raghunathaआयकरअपीलसं./Ita No.: 261/Chny/2025 िनधा"रणवष" / Assessment Year: 2017-18 Mr. Palani, Income Tax Officer, No. 7/5, 3Rd Floor, Meenakshi Vs. Circle (Osd)-1, Apartments, P.S. Sivaswamy Street, Trichy. Mylapore, Chennai 600 004. [Pan: Ahipp3281F] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकरअपीलसं./Ita Nos.: 262 & 263/Chny/2025 िनधा"रणवष" / Assessment Years: 2011-12 & 2012-13 Mrs. Balu Sugunalatha, The Income Tax Officer, No. 7/5, 3Rd Floor, Meenakshi Non Corporate Ward 1(6) Chennai. Apartments, P.S. Sivaswamy Street, Mylapore, Chennai 600 004 Vs. [Pan: Axsps3623E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Ms. Jharna B. Harilal, Ca : ""थ" की ओर से/Respondent By Shri A. Sasikumar, Cit : सुनवाई की तारीख/ Date Of Hearing 19.03.2025 : घोषणा की तारीख /Date Of Pronouncement : 21.03.2025 आदेश /O R D E R Per S. R. Raghunatha: The Appeal Filed By The Assessee In Ita No. 261/Chny/2025 Is Directed Against The Order Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated

Section 131Section 142(1)Section 143(2)Section 144Section 250Section 69A

assessment year 2017-18 for adjudication. 4. Brief facts of the case are that the assessee is an individual and filed his revised return of income on 30.03.2019 for the assessment year 2017- 18. The case was selected for limited scrutiny through CASS to examine large value of cash deposits ... Assessing Officer marked the return filed by the assessee as invalid due to the e-verification not done by the assessee. Further, the revised return submitted by the assessee on 15.05.2015 also marked as invalid for the same reason. No more information is available in the assessment order passed under

Mrs. Balu Sugunalatha, Chennai vs. ITO, Ncw-1(6), Chennai

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

ITA 262/CHNY/2025[2011-12]Status: DisposedITAT Chennai21 Mar 2025AY 2011-12

Bench: Shri George George K., Vice- & Shri S.R. Raghunathaआयकरअपीलसं./Ita No.: 261/Chny/2025 िनधा"रणवष" / Assessment Year: 2017-18 Mr. Palani, Income Tax Officer, No. 7/5, 3Rd Floor, Meenakshi Vs. Circle (Osd)-1, Apartments, P.S. Sivaswamy Street, Trichy. Mylapore, Chennai 600 004. [Pan: Ahipp3281F] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकरअपीलसं./Ita Nos.: 262 & 263/Chny/2025 िनधा"रणवष" / Assessment Years: 2011-12 & 2012-13 Mrs. Balu Sugunalatha, The Income Tax Officer, No. 7/5, 3Rd Floor, Meenakshi Non Corporate Ward 1(6) Chennai. Apartments, P.S. Sivaswamy Street, Mylapore, Chennai 600 004 Vs. [Pan: Axsps3623E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Ms. Jharna B. Harilal, Ca : ""थ" की ओर से/Respondent By Shri A. Sasikumar, Cit : सुनवाई की तारीख/ Date Of Hearing 19.03.2025 : घोषणा की तारीख /Date Of Pronouncement : 21.03.2025 आदेश /O R D E R Per S. R. Raghunatha: The Appeal Filed By The Assessee In Ita No. 261/Chny/2025 Is Directed Against The Order Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated

Section 131Section 142(1)Section 143(2)Section 144Section 250Section 69A

assessment year 2017-18 for adjudication. 4. Brief facts of the case are that the assessee is an individual and filed his revised return of income on 30.03.2019 for the assessment year 2017- 18. The case was selected for limited scrutiny through CASS to examine large value of cash deposits ... Assessing Officer marked the return filed by the assessee as invalid due to the e-verification not done by the assessee. Further, the revised return submitted by the assessee on 15.05.2015 also marked as invalid for the same reason. No more information is available in the assessment order passed under

Mr. Palani, Chennai vs. ITO, Cirlce(OSD)-1, Trichy

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

ITA 261/CHNY/2025[2017-18]Status: DisposedITAT Chennai21 Mar 2025AY 2017-18

Bench: Shri George George K., Vice- & Shri S.R. Raghunathaआयकरअपीलसं./Ita No.: 261/Chny/2025 िनधा"रणवष" / Assessment Year: 2017-18 Mr. Palani, Income Tax Officer, No. 7/5, 3Rd Floor, Meenakshi Vs. Circle (Osd)-1, Apartments, P.S. Sivaswamy Street, Trichy. Mylapore, Chennai 600 004. [Pan: Ahipp3281F] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकरअपीलसं./Ita Nos.: 262 & 263/Chny/2025 िनधा"रणवष" / Assessment Years: 2011-12 & 2012-13 Mrs. Balu Sugunalatha, The Income Tax Officer, No. 7/5, 3Rd Floor, Meenakshi Non Corporate Ward 1(6) Chennai. Apartments, P.S. Sivaswamy Street, Mylapore, Chennai 600 004 Vs. [Pan: Axsps3623E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Ms. Jharna B. Harilal, Ca : ""थ" की ओर से/Respondent By Shri A. Sasikumar, Cit : सुनवाई की तारीख/ Date Of Hearing 19.03.2025 : घोषणा की तारीख /Date Of Pronouncement : 21.03.2025 आदेश /O R D E R Per S. R. Raghunatha: The Appeal Filed By The Assessee In Ita No. 261/Chny/2025 Is Directed Against The Order Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated

Section 131Section 142(1)Section 143(2)Section 144Section 250Section 69A

assessment year 2017-18 for adjudication. 4. Brief facts of the case are that the assessee is an individual and filed his revised return of income on 30.03.2019 for the assessment year 2017- 18. The case was selected for limited scrutiny through CASS to examine large value of cash deposits ... Assessing Officer marked the return filed by the assessee as invalid due to the e-verification not done by the assessee. Further, the revised return submitted by the assessee on 15.05.2015 also marked as invalid for the same reason. No more information is available in the assessment order passed under

Strides Pharma Science Limited, Mumbai vs. Income Tax Officer, 15(3)(2), Mumbai

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

ITA 5721/MUM/2024[2020-21]Status: DisposedITAT Mumbai20 Mar 2025AY 2020-21

Bench: Shri Amit Shukla & Smt. Renu Jauhriआयकर अपील सं./Ita No.5721/Mum/2024 (निर्धारण वर्ष / Assessment Year :2020-21) Strides Pharma Science Limited V/S. Ito 15(3)(2), बनाम Aayakar Bhavan, New 201, Devavrata, Sector-17, Marine Lines, Mumbai-400020 Vashi, Navi Mumbai, Maharashtra-400703 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Blrs03808A .. Appellant/अपीलार्थी Respondent/प्रतिवादी निर्धारिती की ओर से /Assessee By: Shri Nishit Gandhi राजस्व की ओर से /Revenue By: Mr. R. A. Dhyani सुनवाई की तारीख / Date Of Hearing 16.01.2025 20.03.2025 घोषणा की तारीख/Date Of Pronouncement आदेश / Order Per Renu Jauhri [A.M.] :- This Appeal Is Filed By The Assessee Against The Order Of The Learned Commissioner Of Income-Tax (Appeals), Mumbai/National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”] Dated 06.09.2024 Passed U/S.250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “Act”] For

For Appellant: Shri Nishit GandhiFor Respondent: Mr. R. A. Dhyani
Section 143(3)Section 144Section 14ASection 250Section 35Section 37(1)

Strides Pharma Science Limited deemed income u/s 115JB of the Act of Rs.129,55,76,399/-. Subsequently, the assessee filed a revised return on 25.03.2021 declaring a total income of Rs. 62,76,46,192/- and deemed income u/s 115JB of Rs.129,55,76,398/- and the assessment was completed