2015 (3) TMI 1380

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....s Appeal under section 260A of the Income Tax Act, 1961 challenges the order dated 19.10.2012 passed by the Income Tax Appellate Tribunal (for short the 'Tribunal'). The impugned order is passed in respect of the block period of 1.4.1987 to 8.12.1997. 2. This Appeal was on board on 23.2.2015. At that time learned counsel for the appellantassessee pressed the following questions of law f....

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....ve view of the matter, we had passed an order dated 23.2.2015 putting the respondents to notice that on the next occasion Appeal would be taken up for final disposal at the stage of admission itself. 5. We find that the impugned order of the Tribunal while rejecting the petitioner's grounds 1,2 and 3 records as under : 3. " It is seen that ground nos.1,2 and 3 in the GOA filed befo....

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....cted." 6. It is undisputed that the ground nos. 1, 2 and 3 had been raised as additional grounds before the CIT (Appeals) by the Appellant. The CIT (Appeals) in its order dated 25.2.2011 rejected the three additional grounds of appeal on the ground that omission to take these grounds originally in Appeal is wilful and unreasonable. The grievance of the assessee before the Tribunal is precisely ....

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....ion as grounds of appeal which were raised by the appellant before the CIT (Appeals) we find that this was not the basis of the Tribunal dismissing the appeal in respect of grounds 1,2 and 3. The submission on the part of the revenue is hypertechnical and not appreciated as it defeats the purpose and object of the hierarchy of authorities created under the Act to redress the grievances of the asse....