https://www.taxtmi.com/article/detailed?id=16193 Tax litigation strategy must be framed at the adjudication stage, because a party may be restricted from shifting to an entirely different factual defence for the first time on appeal. Appellate proceedings are not intended to rebuild the factual foundation of the dispute or to fill evidentiary gaps left earlier. Pure questions of law may be raised at any stage, but issues requiring factual determination and evidence should first be placed before the adjudicating authority. en-us Mon, 13 Apr 2026 07:55:36 +0530 Mon, 13 Apr 2026 07:55:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=16193 Tax litigation strategy must be framed at the adjudication stage, because a party may be restricted from shifting to an entirely different factual defence for the first time on appeal. Appellate proceedings are not intended to rebuild the factual foundation of the dispute or to fill evidentiary gaps left earlier. Pure questions of law may be raised at any stage, but issues requiring factual determination and evidence should first be placed before the adjudicating authority. Articles Goods and Services Tax - GST Mon, 13 Apr 2026 07:55:36 +0530 https://www.taxtmi.com/article/detailed?id=16193