whichever is earlier: Provided that where the return relates to the previous year relevant to the assessment year commencing on the 1st day of April, 1988, or any earlier assessment year, the reference to one year aforesaid shall be construed as a Civil Appeal No.6274 of 2013 Page 5 of 7reference to two years from the end of the relevant assessment year.” (emphasis added) In the case of Wipro Limited3, in paragraph no.9, this Court held thus: “9. In such a situation, filing a revised return under section 139(5) of the Income-tax Act claiming carrying forward of losses subsequently would not help the assessee. In the present case, the assessee filed its original return under section 139(1) and not under section 139(3). Therefore, the Revenue is right in submitting that the revised return filed by the assessee under section 139(5) can only substitute its original return under section 139(1) and cannot transform it into a return under section 139(3), in order to avail of the benefit of