In the result, the appeal of Revenue in ITA
Bench: Shri Rama Kanta Panda & Shri Laliet Kumar
80A (5) of the Act, the Petitioners could have maintained the claim of deduction even before the CIT for the first time in Revision Application, though no such claim was made before the Assessing Officer, if from the facts on record, the Petitioners could sustain the said claim in law. This is very clear from the series of Judgments