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Issues: Whether the memorandum of appeal could be amended to incorporate the legal grounds relating to the notification and tariff item and to correct the respondent's description.
Analysis: Amendment of pleadings may be permitted at any stage, including the appellate stage, where it is necessary for proper adjudication and does not prejudice the opposite party. The proposed additions concerned the legal basis already underlying the case and did not introduce any new prejudicial matter. The correction of the respondent's name was only a jurisdictional and procedural rectification and similarly caused no prejudice.
Conclusion: The amendment application was allowed and permission was granted to file the supplementary memorandum of appeal.