Assessee Challenges Tribunal's Focus on Legal Grounds Over Substantial Justice u/ss 158BC and 158BD Jurisdiction.

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....Rectification u/s 254 - Assessment proceedings u/s 158BC - jurisdiction questioned by the assessee with reference to Section 158BD - it is the Tribunal which has committed error in restricting itself to legal ground and in not addressing itself on certain other grounds of substantial nature without any fault attributable to the assessee. In such a situation, the cause of substantial justice deserves to be preferred over the technical considerations pitted against it by way of limitation, to shun an apparent miscarriage of justice. - Remedy sought by the assessee can not be frustrated on the grounds of bar of limitation without weighing the circumstances of the case. - AT....