Authorities below were justified in not accepting the return filed in response to notice under section 148 declaring income lower than shown in the original return. Assesse cannot raise fresh independent claims having effect of reducing income already declared. Followed CIT v. Sun Engineering Works Pvt. Ltd. (1992) 198 ITR 297 (SC) (AY 2010-11)
Ratnagiri District Central Co-Operative Bank Ltd. v DCIT (2019) 197 TTJ 649/175 DTR 327 ( Pune) (Trib.)
S. 148 : Reassessment–Notice–Return filed in response offering lesser income- Assesse cannot raise fresh independent claims having effect of reducing income already declared. [S. 147]