Court held that Claims though not raised in return or revised return, the Appellate Authorities must consider the claim if facts are on record the fundamental legal principle is that there is no estoppel in taxation law. An alternative plea can be raised and it can even be a plea which is contradictory to the earlier plea. (AY. 2006-07)
Areva T & D India Ltd. v. CIT (2020) 428 ITR 1 / 317 CTR 633 / 195 DTR 361 (Mad.)(HC)
S. 254(1) : Appellate Tribunal-Duties-Claims though not raised in return or revised return-Appellate Authorities must consider the claim if facts are on record-There is no estoppel in taxation law- Contradictory claim can be raised. [S. 250]