https://www.taxtmi.com/caselaws?id=8660 Under section 63(3) of the Estate Duty Act, 1953, the appellate power is wide, but a person seeking to raise fresh grounds for the first time on appeal must give a proper and satisfactory explanation for not advancing them earlier. If the new contention is inconsistent with the stand taken before the assessing authority and no adequate reason is shown for the omission, the appellate authority may judicially refuse leave to raise it. On the stated facts, the accountable person had proceeded on the basis that the properties belonged to the deceased individually and later sought to claim some were ancestral and linked to a Hindu undivided family, without explaining the change. The refusal to admit the fresh grounds was upheld. en-us Fri, 21 Apr 1972 00:00:00 +0530 Wed, 20 May 2009 16:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8660 Under section 63(3) of the Estate Duty Act, 1953, the appellate power is wide, but a person seeking to raise fresh grounds for the first time on appeal must give a proper and satisfactory explanation for not advancing them earlier. If the new contention is inconsistent with the stand taken before the assessing authority and no adequate reason is shown for the omission, the appellate authority may judicially refuse leave to raise it. On the stated facts, the accountable person had proceeded on the basis that the properties belonged to the deceased individually and later sought to claim some were ancestral and linked to a Hindu undivided family, without explaining the change. The refusal to admit the fresh grounds was upheld. Case-Laws Income Tax Fri, 21 Apr 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8660