Appellate Tribunal allows amendment of grounds to address time-bar issue. Mixed fact-law question considered.

The Appellate Tribunal CEGAT, Kolkata allowed the appellant to amend the grounds of appeal to include the issue of time-bar, which was not addressed by the Commissioner (Appeals). This decision was made as the issue involved a mixed question of fact and law.

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The Appellate Tribunal CEGAT, Kolkata allowed two Miscellaneous Applications to amend the ground number (1) by introducing an aspect of time-bar. The issue of time-bar was not discussed by the Commissioner (Appeals) but the appellant was allowed to raise it as it is a mixed question of fact and law.

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