The Supreme Court has ruled that a taxpayer cannot raise a fresh claim before a Revisional authority under the Income Tax Act without first filing a revised return within the prescribed time. The Court held that bypassing the revised return procedure and directly approaching the revisional forum is impermissible. This decision reinforces procedural discipline in income tax proceedings and closes a route that assessees had used to introduce new claims at the appellate or revisional stage without amending their original returns.

This ruling addresses a recurring tension in income tax law: whether an assessee who omits a deduction or exemption claim in the original return can introduce that claim for the first time at the revisional stage, without filing a revised return under Section 139(5) of the Income Tax Act, 1961.

The Supreme Court's answer is an unequivocal no. The revisional authority — typically the Commissioner of Income Tax (Appeals) or the Principal Commissioner under Sections 263/264 of the Income Tax Act — exercises supervisory jurisdiction over assessment orders. It is not a forum for introducing entirely new claims that were never part of the original return.

The logic is procedural and structural: the return of income is the foundational document of assessment. If an error or omission occurs, the statute provides a specific remedy — filing a revised return under Section 139(5) before the relevant deadline. Allowing fresh claims at the revisional stage without this step would circumvent the statutory scheme, create asymmetry between taxpayers who follow procedure and those who do not, and burden the revisional forum with adjudicating claims the Assessing Officer never had the chance to consider.

This principle connects to administrative law's doctrine of exhaustion of statutory remedies and the rule that appellate/revisional bodies cannot travel beyond the record below. For CLAT PG aspirants, the examiner is likely to test this as a passage-based MCQ where the principle must be applied to a hypothetical involving a missed deduction claim.