Binding appellate directions require deduction to be allowed; assessment-stage limits cannot override Tribunal-granted relief.

An Assessing Officer cannot refuse a deduction merely because it was not separately debited in the return or profit and loss account when the Tribunal has already allowed the underlying claim on identical facts. The restriction against entertaining fresh claims applies at the assessment stage, but it does not permit the assessing authority to disregard a binding appellate direction. Once appellate relief has been granted, the consequential deduction must be implemented, and the disallowance cannot be sustained.

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Issues: Whether the Assessing Officer could deny the deduction directed by the Tribunal on the ground that the claim was not separately debited in the return or profit and loss account.

Analysis: The deduction had already been allowed by the Tribunal on identical facts, and the Assessing Officer was only required to give effect to that decision. A claim that is otherwise barred at the assessment stage cannot be refused when it flows from a binding appellate direction. The limitation recognised in the doctrine against fresh claims before the assessing authority applies to the Assessing Officer, not to relief mandated by the Tribunal or Court. Once the Tribunal had allowed the ground, the consequential deduction had to be granted.

Conclusion: The Assessing Officer could not sustain the disallowance, and the deduction was required to be allowed in favour of the assessee.

Final Conclusion: The impugned order was quashed to the extent it denied the deduction, and consequential relief was directed to be granted.

Ratio Decidendi: A claim rejected at the assessment stage cannot be denied when a binding appellate order has already allowed the underlying deduction, because the restriction on entertaining fresh claims is confined to the assessing authority and does not override the duty to implement appellate directions.

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