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| The Tax Publishers2022 TaxPub(DT) 0711 (Bang-Trib) : (2022) 093 ITR (Trib) 0101 INCOME TAX ACT, 1961
Section 254(1)
Assessee challenged inclusion of certain companies in the list of comparables by way of additional ground raised before ITAT. All the material facts relating to additional grounds were already available on record and there was no question of investigation into fresh facts so as to adjudicate the same. Accordingly additional grounds were admitted for adjudication.
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Appeal (Tribunal) - Admissibility of additional ground - Material facts available on record calling for no investigation into fresh facts -
Assessee having entered into international transactions with its AE abroad challenged inclusion of certain companies in the list of comparables by way of additional ground raised before ITAT. Held: All the material facts relating to additional grounds were already available on record and there was no question of investigation into fresh facts so as to adjudicate the same. Accordingly additional grounds were admitted for adjudication.
Followed:National Thermal Power Co. Ltd. v. CIT (1998) 229 ITR 383 (SC) : 1998 TaxPub(DT) 342 (SC).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2010-11
INCOME TAX ACT, 1961
Section 92C
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