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Deduction u/s 80IA - first time claimed in the revised return - Amendment vide Finance Act, 2020 - this issue was never an issue pointed out to the assessee at any earlier point of time and it appears that the issue had been taken up for consideration when the case was heard and orders were reserved by the learned Tribunal. In any event, such point could not have been put against the assessee when the same was never the case of the revenue before the Tribunal. - HC