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5.2 In the written submission, on the other hand, furnished during the appellate stage, the appellant has stated the following:

"B. Ground No.2 - The assessment order passed by the AO u/sec.143(3) of the Act is bad in law as the learned AO ignored the submissions made by the appellant trust, which is against the principle of natural justice.

And Ground No.3 - The learned AO has failed to appreciate the valid revised return filed by the appellant trust in Form ITR-5 and has made the additions on the basis of original return of income filed by the appellant trust in Form ITR-7.

4. Without prejudice, the learned CIT(A) ought to have allowed deduction of proportionate expenditure incurred in relation to the earning of interest income, even if such income were to be treated as taxable, in accordance with settled principles of law.

5. The learned CIT(A) further erred in not considering that the revised return of income filed in Form ITR-5, claiming exemption on the principle of mutuality, was validly filed under section 139(5) of the Act, and hence the assessment as well as appellate order ought to have been framed in accordance with the said revised return.