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| The Tax Publishers2021 TaxPub(DT) 1072 (Chen-Trib) INCOME TAX ACT, 1961
Section 254(1)
Additional ground raised by assessee was purely a legal ground for which there was no requirement of examining any facts and hence additional grounds of appeal filed by assessee were admitted by ITAT.
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Appeal (Tribunal) - Additional ground - Legal nature -
Assessee by way of additional ground raised before ITAT challenged reassessment proceedings in light of notice issued under section 148 before expiry of time-limit for issue of notice under section 143(2). Revenue opposed to admission of additional grounds filed by assessee. Held: Additional ground raised by assessee was purely a legal ground for which there was no requirement of examining any facts and hence additional grounds of appeal filed by assessee were admitted.
Followed:National Thermal Power Corporation Ltd. v. CIT (1998) 229 ITR 383 (SC) : 1998 TaxPub(DT) 342 (SC)
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 143(3) Section 147
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