Chapter VI-C deduction requires a claim in the return; appellate authorities cannot bypass the statutory bar.

Deduction under Chapter VI-C could not be allowed unless claimed in the return of income, because section 80A(5) imposes an express statutory bar on unclaimed deductions. The assessee's attempt to raise the claim during assessment or as an additional ground before the appellate authorities did not cure that defect, since appellate powers remain subject to the Act's limitations. Even if the deduction was otherwise allowable on merits, it was not admissible without compliance with the statutory precondition, and the claim was rejected.

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Issues: Whether deduction under section 80P(2)(d) of the Income-tax Act, 1961 could be allowed when the claim was not made in the return of income, in view of section 80A(5) of the Income-tax Act, 1961; and whether such a claim could be entertained as an additional ground before the appellate authorities.

Analysis: The deduction claimed by the assessee fell within Chapter VI-C, and section 80A(5) mandates that no such deduction shall be allowed unless the claim is made in the return of income. The fact that the assessee sought to raise the claim during assessment proceedings or as an additional ground before the appellate authorities did not override this statutory restriction. The appellate authorities have wide powers to admit new grounds, but those powers remain subject to the express limitations imposed by the Act. Accordingly, even assuming the claim could otherwise be allowable on merits, it could not be granted because the statutory precondition was not satisfied.

Conclusion: The claim for deduction was not admissible, and the issue was decided against the assessee.

Final Conclusion: The common order affirms that deductions under Chapter VI-C cannot be granted unless specifically claimed in the return of income, and an appellate forum cannot allow a claim barred by the statute.

Ratio Decidendi: A deduction falling under Chapter VI-C of the Income-tax Act, 1961 cannot be allowed unless it is claimed in the return of income, and appellate authorities cannot grant such a claim in contravention of section 80A(5).

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