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| The Tax Publishers2022 TaxPub(DT) 5142 (Mum-Trib) INCOME TAX ACT, 1961
Section 254(1)
Assessee by way of additional ground of appeal raised before ITAT pleaded that reopening proceedings initiated under section 147 were invalid and bad-in-law. The issue was purely legal in nature and no investigation of fresh facts was required and, therefore, additional grounds was admitted for adjudication.
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Appeal (Tribunal) - Additional ground - Legal issue -
Assessee by way of additional ground of appeal raised before ITAT pleaded that reopening proceedings initiated under section 147 were invalid and bad-in-law. Held: Additional ground raised was purely legal in nature and no investigation of fresh facts was required and, therefore, additional grounds was admitted for adjudication.
Followed:<.b>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 147
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