Fresh claim can be made before the appellate authorities if the assessee demonstrates that he was unable to make such a claim through a revised return. Hence the matter was restored back to the AO. (ITA Nos. 30 to 32/Coch/2016 dt. 23.11.2017) (AY. 2009-10 to 2011-12)
HLL Lifecare Limited v. ACIT (2018) 191 TTJ 1(UO) / 66 ITR 361 (Cochin) (Trib.)
S. 251 : Appeal – Commissioner (Appeals) – Powers- Fresh claim can be made before the appellate authorities if the assessee demonstrates that he was unable to make such a claim through a revised return. [S. 35D,139(5)]