inconsistent or contrary plea or a new claim. We are not impressed by this argument. For, the observations in the decision in Goetze (India) Ltd. itself make it amply clear that such limitation would apply to the “assessing authority”, but not impinge upon the plenary powers of the ITAT bestowed under Section 254 of the Act. Civil Appeal No.6274 of 2013 Page 4 of 7In other words, this decision is of no avail to the department.” (emphasis added) In this case, the Court did not consider the question of the power of the assessing officer to consider a claim made after a revised return was barred by time. This Court considered the appellate powers of the Tribunal under Section 254 of the IT Act. Moreover, this was a case where the department gave no objection for enabling the assessee to set up a fresh claim. 6. In the case of Goetzge (India) Ltd2, this Court held that the assessing officer cannot entertain any claim made by the assessee otherwise than by following the provisions of the