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of <h1>Appellants must stick to appeal grounds unless Tribunal allows; Tribunal can consider other grounds with fair hearing.</h1> Rule 11 of the Income-tax (Appellate Tribunal) Rules, 1963, specifies that an appellant cannot argue any grounds not included in the memorandum of appeal without the Tribunal's permission. However, the Tribunal is not limited to these grounds when deciding an appeal. It can consider other grounds, provided that any party potentially affected by these grounds is given a fair chance to be heard. This ensures that all relevant matters are considered while safeguarding the rights of affected parties.
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