Courts Supreme Court
Supreme Court bars fresh tax claims without timely revised return
The case concerns whether an assessee can raise a fresh claim before a Revisional Authority under the Income Tax Act without having filed a timely revised return.
The Supreme Court held that such a claim cannot be raised in the absence of a valid revised return.
Who it concerns: Appellant: Orissa Rural Housing Development Corporation Ltd.; Respondents: The Asst. Commissioner of Income Tax & Ors.; Bench: Justices Prashant Kumar Mishra and Shree Chandrashekar.
What the court decided
- Dismissed Civil Appeal Nos. 7249-7250/2015.
- Held that a fresh claim cannot be raised before the Revisional Authority if a revised return was not filed within the time prescribed by law.
- Relied on the precedent set in M/s. Om Siddhakala Associates (2026) to distinguish earlier cases like Wipro Finance Ltd.
- Disposed of any pending applications.
Also in the document
- The Court clarified that the power of the Revisional Authority is limited to entertaining new questions of law based on existing facts, not to entertain fresh claims based on new facts not before the Assessing Officer.
- The Court noted that allowing fresh claims without a timely revised return would make the assessment procedure endless.
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The original document
Supreme Court of India — orders & judgments
Court order · 13 Oct 2026
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