https://www.taxtmi.com/caselaws?id=27713 The Tribunal's power to admit a new ground is confined to the subject-matter of the appeal as defined by what the Appellate Assistant Commissioner expressly or impliedly decided, so a contention not raised before the departmental authorities and unsupported by any factual foundation cannot be introduced for the first time before the Tribunal. The High Court also applied its earlier ruling in Elecon Engineering Co. Ltd. and held that one-half of the relevant year's profits could be included in computing capital employed for statutory relief. The reference was therefore answered against the Revenue on the new-ground issue and in favour of the assessee on profit inclusion. en-us Mon, 03 Oct 1977 00:00:00 +0530 Mon, 15 Feb 2010 15:35:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27713 The Tribunal's power to admit a new ground is confined to the subject-matter of the appeal as defined by what the Appellate Assistant Commissioner expressly or impliedly decided, so a contention not raised before the departmental authorities and unsupported by any factual foundation cannot be introduced for the first time before the Tribunal. The High Court also applied its earlier ruling in Elecon Engineering Co. Ltd. and held that one-half of the relevant year's profits could be included in computing capital employed for statutory relief. The reference was therefore answered against the Revenue on the new-ground issue and in favour of the assessee on profit inclusion. Case-Laws Income Tax Mon, 03 Oct 1977 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27713