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| The Tax Publishers2019 TaxPub(DT) 6723 (Chd-Trib) INCOME TAX ACT, 1961
Section 253
Where additional ground raised by assessee was purely a legal ground and relevant material was available on record, such additional ground would be admissible.
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Appeal (Tribunal) - Admissibility - Additional ground - Ground being pure question of law
Assessee raised additional ground before Tribunal and requested to admit the same by stating that it was purely a question of law. Revenue opposed the admission of additional ground and submitted that the assessee neither raised such ground before AO or CIT (A), therefore, it would not be admitted before the Tribunal. Held: Since additional ground raised by assessee was purely a legal ground and relevant material was available on record, in view of Apex Court decision in the case of National Thermal Power Co. Ltd. (NTPC) v. CIT (1998) 229 ITR 383 (SC): 1998 TaxPub(DT) 0342 (SC), such additional ground would be admissible.
Relied:Apex Court decision in the case of National Thermal Power Co. Ltd. (NTPC) v. CIT (1998) 229 ITR 383 (SC): 1998 TaxPub(DT) 0342 (SC)
REFERRED :
FAVOUR : In assessee's favour
A.Y. : 2015-16
INCOME TAX ACT, 1961
Section 143(3)
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