https://www.taxtmi.com/caselaws?id=789451 New factual grounds that alter the nature of a dispute cannot be raised for the first time at the second appellate stage; only pure legal grounds may be urged at any stage. An attempt to introduce a case that the activity amounted to manufacture rather than provision of service, together with additional documents supporting that factual foundation, was therefore not entertainable, as it would fill lacunae and bypass prior examination. The miscellaneous applications were held not maintainable and were rejected. en-us Tue, 07 Apr 2026 00:00:00 +0530 Thu, 09 Apr 2026 08:09:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789451 New factual grounds that alter the nature of a dispute cannot be raised for the first time at the second appellate stage; only pure legal grounds may be urged at any stage. An attempt to introduce a case that the activity amounted to manufacture rather than provision of service, together with additional documents supporting that factual foundation, was therefore not entertainable, as it would fill lacunae and bypass prior examination. The miscellaneous applications were held not maintainable and were rejected. Case-Laws Service Tax Tue, 07 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789451