furnished Note claiming to be reasons for filing
revised return. The Note to the revised return is as under:
As on 31st March ... valid revised return u/s. 139(5) . Importantly, the
revised return is filed based on revised computation of income. No
revised audit report has been
scrutiny assessment. Later, revised return of
Income was filed on 16.11.2015. Even if the revised return of
income is a valid return, the scrutiny assessment ... file a revised return and say that the revised return has
substituted the original return and, therefore, the pending scrutiny
assessment proceedings initiated
scrutiny assessment. Later, revised return of
Income was filed on 16.11.2015. Even if the revised return of
income is a valid return, the scrutiny assessment ... file a revised return and say that the revised return has
substituted the original return and, therefore, the pending scrutiny
assessment proceedings initiated
that the revised return is not a valid revised return.
And once, revised return is a valid return, subsequent proceedings i.e. reference ... along with the revised
return of income. Hence, we treat the revised return of income filed by assessee as a valid
revised return filed within
revised return. The assessee has also given his Explanation
for filing the said revised return. In fact, after the said revised return was filed, notice ... that if a revised return is filed u/s.139(5) and if such return
is a valid return then the assessment can be completed
original
return is substituted by the revised return as a result of the amendments made in the
original return by the revised return ... according to the learned counsel, it was held that once a valid revised return is filed,
it cannot be open to the Assessing Officer
revised return of income before filing
the revised return of income.
vi) that the A.O. has taken cognizance of the said revised
return ... revised .return substitutes itself in its place, it becomes a
return under s. 139(1) . Therefore, a second revised return can
be filed under
original return of income
filed on 28.11.2016.
(ii) The claim made in the revised return of income is not
valid for the reason that ... which according to
the Assessing Officer, is not a valid revised return for the reason
that there is no bona-fide omission or mistake
concluding that
(i) the revised return filed by the appellant is an invalid return;
(ii) loss as per the revised return cannot be carried forward ... time limit prescribed and
subsequently, files the revised return then the revised return is
treated as valid return. In the present case, as the assessee
lakhs or more for three AYs; (iii) Assessee filed the
returns/revised returns validly complying with the admission made during the
survey action; (iv) assessee ... claim made in the return cannot amount to furnishing inaccurate
particulars. "
Thus, the return of income or valid revised return is the basis
