https://www.taxtmi.com/caselaws?id=787579 Admissibility of additional legal grounds filed late was permitted because they raised pure questions of law apparent on the record and caused no prejudice; the Tribunal exercised plenary power to admit them. On the principal issue, material seized in third party search proceedings that was not before the appellate authority at the time of set aside falls within the search/undisclosed income regime and must be processed under the statutory search assessment procedure; using such material to complete a regular set aside assessment exceeded the AO's jurisdiction and rendered that assessment invalid, leading to dismissal of the Revenue's appeal. en-us Fri, 06 Mar 2026 00:00:00 +0530 Mon, 09 Mar 2026 10:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787579 Admissibility of additional legal grounds filed late was permitted because they raised pure questions of law apparent on the record and caused no prejudice; the Tribunal exercised plenary power to admit them. On the principal issue, material seized in third party search proceedings that was not before the appellate authority at the time of set aside falls within the search/undisclosed income regime and must be processed under the statutory search assessment procedure; using such material to complete a regular set aside assessment exceeded the AO's jurisdiction and rendered that assessment invalid, leading to dismissal of the Revenue's appeal. Case-Laws Income Tax Fri, 06 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787579