Tribunal Can Address New Grounds in Tax Cases u/s 254, Including Fresh Claims via Rectification Applications.

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....Fresh claim before the Assessing Officer by way of a rectification application - there is no bar on the higher authorities and especially upon this Tribunal in exercising its power u/s 254 of the Income Tax Act to entertain or to deal not merely with additional ground which became available on account of change of circumstances or law, but with additional grounds which were available when the return was filed. - AT....