Specific grounds are required to challenge comparable companies; a general objection was insufficient and the modification request failed.

A general cross objection challenging the acceptance of comparable companies was insufficient to require the Tribunal to examine exclusion of three named comparables. Because no specific ground sought their exclusion, the Tribunal had no occasion to adjudicate their comparability on that basis. The request for modification was therefore rejected, and the issue was decided against the assessee.

---

---

Issues: Whether the Tribunal was required to return a finding on the exclusion of three comparable companies when the cross objection raised only a general ground challenging the acceptance of comparable companies.

Analysis: The cross objection contained only a broad grievance that the CIT(A) had accepted certain comparable companies by applying unreasonable comparability criteria. No specific ground was raised seeking exclusion of the named companies. In the absence of a specific issue having been raised, there was no occasion for the Tribunal to adjudicate comparability of those three companies.

Conclusion: The issue was answered against the assessee, and the request for modification was rejected.

---