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| The Tax Publishers2020 TaxPub(DT) 5258 (Del-Trib) INCOME TAX ACT, 1961
Section 254(1)
Additional ground raised, i.e, validity of reassessment framed by AO being a legal ground went to the root of the matter, and the same was, therefore, admitted.
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Appeal (Tribunal) - Additional ground - Admissibility - Assessee challenged validity of reassessment on the ground of non-furnishing of reasons
Assessee by way of additional ground raised before ITAT challenged validity of reassessment framed by AO on the ground of AO not having furnished reasons recorded for reopening to assessee. Held: Additional ground raised being a legal ground went to the root of the matter, and the same was, therefore, admitted.
Relied:National Thermal Power Co. Ltd. v. CIT on 4-12-1996 : (1998) 229 ITR 383 (SC) : 1998 TaxPub(DT) 342 (SC).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2002-03
INCOME TAX ACT, 1961
Section 147
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