1991 (5) TMI 20

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.... section 256(2) of the Income-tax Act, 1961, filed at the instance of the Revenue. Two questions have been proposed in this application. The controversy raised revolves around the question whether the Income-tax Appellate Tribunal, in law, could permit the assessee to raise the plea of jurisdiction for the first time before it which was not raised earlier either before the Assessing Officer or bef....