The appellate authority has coterminous power to accept the deduction which was not claimed in ITR. So, the entire claim under section 80C is eligible for claim of deduction. Followed: CIT, Delhi-II v. Jai Parabolic Springs Ltd [2008] 172 Taxman 258/ 306 ITR 42 (Delhi HC) Sesa Goa Ltd. v. Additional CIT, Panaji, Goa, [2020] 117 taxmann.com 548 (Bom)(HC). Distinguished: Goetze (India) Ltd. v. CIT [2006] 284 ITR 3231 (SC) (AY. 2015-16 to AY. 2018-19)
Ajay Sharma v. Jt. CIT [2024] 109 ITR 268 (Amritsra)(Trib)
S. 251: Appeal -Commissioner (Appeals) -Powers- Co-terminus -Fresh claim of deduction- Allowed deduction. [S.80C]