Appellants must engage early; Tribunal not a first-stop for cases ignored in lower proceedings.

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....Best judgment assessment u/s 144 - additions towards unexplained money u/s. 69A r.w.s.115BBE - - In no case can the Tribunal be taken as a forum for an appellant who, as per his volition, had either adopted an evasive or lackadaisical approach before the lower authorities and not participated in the assessment or appellate proceedings to come up with its case for the first time before the Tribunal and, as a matter of right seek restoring of the impugned order to the file of the lower authorities for fresh adjudication. - AT....