Fresh Section 54 claim rejected

The Delhi Bench of the Income Tax Appellate Tribunal dismissed the assessee's appeal and upheld the denial of a deduction under Section 54 of the Income-tax Act, 1961. The Tribunal held that a fresh claim, omitted from the original return, cannot be introduced through a return filed in response to a notice under Section 148, thereby affirming the reassessment framework adopted by the lower authorities.