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August 2026

Denial of claim under section 54F cannot be sustained where the case of the assessee was selected for limited scrutiny with the notice under section 143(2) stating verification of large cash deposits in savings bank account to be the reason therefor. Once a revised return is filed, the original return stands replaced. Consequently, the assessment made on the basis of original return by ignoring the revised return which reduced the total income needs to be quashed.

By Jagdish T Punjabi, Chartered Accountant Devendra Jain & Aditya Bhatt, Advocates
Reading Time 3 mins

36. 2026(6) TMI 1392 – ITAT - Delhi

Paluri Raghavan Gopala v. ACIT

A.Y.: 2015-16 Date of Order : 24.6.2026

Sections: 139, 143

Denial of claim under section 54F cannot be sustained where the case of the assessee was selected for limited scrutiny with the notice under section 143(2) stating verification of large cash deposits in savings bank account to be the reason therefor.

Once a revised return is filed, the original return stands replaced. Consequently, the assessment made on the basis of original return by ignoring the revised return which reduced the total income needs to be quashed.

FACTS

The assessee preferred an appeal against the appellate order passed under section 250 of the Act by National Faceless Appeal Centre confirming the additions made by the Assessing Officer while assessing the total income of the assessee under section 143(3) of the Act.

Aggrieved, the assessee preferred an appeal where it raised two additional grounds viz. (i) that the CIT(A) erred in confirming the addition to total income as a result of disallowa

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