https://www.taxtmi.com/caselaws?id=6664 Whether the ITAT exercised its appellate discretion under rule 12 and section 66(2) to admit an additional ground turned on whether the new plea was a pure question of law or required factual inquiry. The Court noted that issues such as source of cash credit, maintenance of accounts and prior option would necessitate factual investigation; the ground had not been raised earlier, no adequate explanation for delay was offered, and bona fides were doubtful. Because the Tribunal gave reasons logically connected to these considerations, its refusal to admit the ground was judicially exercised and is upheld. en-us Fri, 05 Nov 1965 00:00:00 +0530 Sat, 31 Jan 2009 16:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6664 Whether the ITAT exercised its appellate discretion under rule 12 and section 66(2) to admit an additional ground turned on whether the new plea was a pure question of law or required factual inquiry. The Court noted that issues such as source of cash credit, maintenance of accounts and prior option would necessitate factual investigation; the ground had not been raised earlier, no adequate explanation for delay was offered, and bona fides were doubtful. Because the Tribunal gave reasons logically connected to these considerations, its refusal to admit the ground was judicially exercised and is upheld. Case-Laws Income Tax Fri, 05 Nov 1965 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6664