Section 2 of the Income Tax Act

The Assessing Officer must consider fresh claims made during assessment proceedings, as income tax proceedings are not adversarial and income should be computed according to law, unless a statutory bar exists. The Supreme Court's decision in Goetze (India) Ltd. does not restrict appellate authorities from entertaining new claims.

The Assessing Officer cannot make a prima facie adjustment to the total income under Section 143(1)(a) if the adjustment involves a debatable issue.