Additional deduction claims may be admitted before the Tribunal when facts are already on record, with remand for fresh consideration.

An additional claim for deduction of bad debts, raised during assessment and supported by facts already on record, could be entertained by the Tribunal even though it was not made through a revised return. The Tribunal applied the principle that Goetze (India) Ltd. does not restrict its power to admit an additional ground or claim where the relevant material is already available. The additional evidence was admitted, and because the merits of the claim had not been examined by the lower authorities, the matter was sent back to the Assessing Officer for fresh consideration after giving the assessee due opportunity.

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Issues: Whether the assessee's additional claim for deduction of bad debts, not made by revised return but supported by facts already on record, could be admitted before the Tribunal and sent back for fresh adjudication on merits.

Analysis: The assessee had raised the claim during assessment proceedings by letter, and the relevant facts were already before the Assessing Officer. The Tribunal held that the restriction noticed in Goetze (India) Ltd. does not curtail the Tribunal's power to entertain an additional ground or claim where the material facts are on record. The Tribunal also admitted the application for additional evidence and found it appropriate that the merits of the claim had not been examined by the lower authorities.

Conclusion: The additional claim was admitted. The issue of deduction for bad debts was set aside to the Assessing Officer for de novo consideration after giving due opportunity to the assessee.

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