https://www.taxtmi.com/caselaws?id=38879 Additional grounds in second appeal cannot be entertained where they rest on a new factual case not raised before the lower authorities and the record lacks the factual foundation needed for determination. The assessee had itself treated the amount as a revenue receipt in its return, and the Tribunal was not required to permit a fresh capital-versus-revenue plea that would need further investigation of facts merely because another assessee's case was cited. The Tribunal was therefore correct in refusing to allow the additional grounds, and the question was answered against the assessee. en-us Thu, 15 Jul 1976 00:00:00 +0530 Sat, 10 Apr 2010 11:25:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38879 Additional grounds in second appeal cannot be entertained where they rest on a new factual case not raised before the lower authorities and the record lacks the factual foundation needed for determination. The assessee had itself treated the amount as a revenue receipt in its return, and the Tribunal was not required to permit a fresh capital-versus-revenue plea that would need further investigation of facts merely because another assessee's case was cited. The Tribunal was therefore correct in refusing to allow the additional grounds, and the question was answered against the assessee. Case-Laws Income Tax Thu, 15 Jul 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38879