The Tax Publishers2019 TaxPub(DT) 4880 (Asr-Trib)

INCOME TAX ACT, 1961

Section 253

Where additional ground raised by assessee did not involve any additional document and/or submissions to substantiate its claim, such additional grounds were liable to be admitted.

Appeal (Tribunal) - Admissibility - Additional ground - Ground being pure question of law

Assessee raised additional grounds before Tribunal and requested to admit the same stating that the said grounds were purely legal in nature for which all relevant facts were on record. Held: Since additional ground raised by assessee did not involve any additional document and/or submissions to substantiate its claim, in view of dictum of Apex Court in the case of National Thermal Power Company Ltd. v. CIT (1998) 229 ITR 383 (SC): 1998 TaxPub(DT) 0342 (SC), the additional grounds were admitted.

Relied:National Thermal Power Company Ltd. v. CIT (1998) 229 ITR 383 (SC): 1998 TaxPub(DT) 0342 (SC)

REFERRED :

FAVOUR : In assessee's favour

A.Y. :


INCOME TAX ACT, 1961

Section 12A

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