Claim to deduction u/s 54B raised first time in appellate proceedings was allowable

ITO Vs Raja Vikram (ITAT Raipur) Conclusion: Where assessee did not raised claim for deduction under section 54B while filing the returns of income filed u/s 139(1) and u/s 148 but in appellate proceedings raised the same then such claim was allowable. Held: During the course of assessment proceedings, it was observed by AO that assessee had both in his Original return of income filed u/s 139(1); as well as that filed in compliance to Notice u/s 148 claimed that the income arising from the transfer of his 1/2 share in agricultural land at Village: Dharampura was not exigible to tax under the A...