New grounds cannot be raised on appeal without a tribunal record; block assessment challenge failed for lack of foundation.

A challenge to a block assessment under section 158BC based on alleged defects in the search authorisation and panchanama could not be entertained for the first time in appeal. Because the objection was not raised before the Tribunal and no supporting material was placed on record, the Court refused to examine the framed substantial question of law. The ruling underscores that a contention not urged or considered at the tribunal stage cannot be introduced later without an evidentiary foundation.

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Issues: Whether the assessee could challenge the block assessment framed under section 158BC of the Income-tax Act on the ground of alleged defects in the search authorisation and panchanama, when no such objection had been raised before the Tribunal.

Analysis: The alleged defect in the search proceedings was not raised before the Tribunal and no material on that aspect had been placed before it. A contention that was never urged or examined at the tribunal stage could not be entertained for the first time in appeal. In the absence of a foundation in the record, the Court declined to examine the substantial question of law framed by the appellant.

Conclusion: The challenge to the block assessment was not maintainable in appeal on the newly raised ground, and the appeal failed.

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