2005 (7) TMI 58

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....ches SMC-IV, New Delhi, whereby the appeal filed by the Department against the order of the Commissioner of Income-tax (Appeals), dated March 20, 2003, has been allowed. On behalf of the appellant it was argued that the Tribunal had fallen in a palpable error in holding that the period for completion of the assessment proceedings, on the basis of the first notice issued to the assessee on March....

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....ad not been advanced before the Tribunal with the result that the Tribunal had proceeded on the assumption that the period for completion of the assessment proceedings expired on March 31, 2000. He urged that instead of the issue being examined by this court for the first time, the matter could be remitted back to the Tribunal to give it an opportunity to deal with the submission now urged on beha....