New factual grounds cannot be raised at the second appellate stage; only pure legal grounds may be urged later.

New factual grounds that alter the nature of a dispute cannot be raised for the first time at the second appellate stage; only pure legal grounds may be urged at any stage. An attempt to introduce a case that the activity amounted to manufacture rather than provision of service, together with additional documents supporting that factual foundation, was therefore not entertainable, as it would fill lacunae and bypass prior examination. The miscellaneous applications were held not maintainable and were rejected.

---

---

Issues: Whether the appellant could be permitted, at the second appellate stage, to introduce new factual grounds and additional documents through the miscellaneous applications.

Analysis: The requested grounds were not merely legal in nature but introduced a new factual case that the appellant's activity amounted to manufacture and not provision of service. Such a contention required prior examination at the lower stages and could not be entertained for the first time before the Tribunal, as doing so would permit filling in lacunae and would alter the nature of the dispute. The request to place additional documents was also tied to this new factual foundation and was therefore not entertainable at this stage.

Conclusion: The miscellaneous applications were not maintainable and were rejected.

Ratio Decidendi: New factual grounds that change the nature of the case cannot be raised for the first time at the second appellate stage, whereas only pure legal grounds may be urged at any stage.

---