ITR
Giving new evidence in a revision reply
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Facts
Yes. You can place documents in the revision proceedings to show the claim was correct on facts. This helps show there was no loss to revenue even if the earlier enquiry was thin.
Provisions and law
- Sec 263, Income-tax Act 1961 (now Sec 377, Income-tax Act 2025)The Principal Commissioner or Commissioner can revise an assessment order that is erroneous and prejudicial to revenue, after giving a hearing, within 2 years from the end of the financial year of the order.
Analysis
Say a deduction of ₹2,00,000 was allowed without proof being asked. In revision, you can file the receipts and bank proof to show the claim is genuine. That weakens the prejudice to revenue condition. Explain why the documents were not filed earlier, such as they were never asked for.
Conclusion
- Collect documents that prove the claim.
- Explain why they were not filed earlier.
- Attach them to the reply with an index.
- Argue that there is no loss to revenue.
A Savvy can do this for you
Revision, Sec 263 (now 377)
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