https://www.taxtmi.com/caselaws?id=39036 The Tribunal's jurisdiction is confined to the subject-matter of the appeal, as defined by the Appellate Assistant Commissioner's express or implied decision. Within that boundary, it may admit new legal grounds supporting the same relief, provided the other side is heard. A claim not raised before the Appellate Assistant Commissioner cannot be treated as part of the appeal unless the underlying factual basis is first established. The section 80J issue therefore depends on whether that contention was actually urged before the Appellate Assistant Commissioner, and the preliminary factual question must be resolved before the appeal is disposed of. en-us Wed, 17 Dec 1975 00:00:00 +0530 Mon, 12 Apr 2010 11:18:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39036 The Tribunal's jurisdiction is confined to the subject-matter of the appeal, as defined by the Appellate Assistant Commissioner's express or implied decision. Within that boundary, it may admit new legal grounds supporting the same relief, provided the other side is heard. A claim not raised before the Appellate Assistant Commissioner cannot be treated as part of the appeal unless the underlying factual basis is first established. The section 80J issue therefore depends on whether that contention was actually urged before the Appellate Assistant Commissioner, and the preliminary factual question must be resolved before the appeal is disposed of. Case-Laws Income Tax Wed, 17 Dec 1975 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39036