S. 254(1) : Appellate Tribunal – Duties- Oral application – Subject matter of appeal – Order passed by the ITAT suffered from perversity in so far as it refused to allow the assessee to urge the grounds by way of an oral application under Rule 27 of the ITAT Rules – Matter remanded back before the ITAT with a direction to hear the matter afresh by allowing the assessee to raise the additional grounds [ S.153C, ITAT Rules , R.27 ]