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 fro

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