The Tribunal that the validity of the assessment can be challenged at any time as it goes to the root of the matter and is a legal issue. Since all the facts are on record, it can be admitted at this stage. (AY. 2004-05, 2006-07 & 2007-08)
Cyient Ltd. v. Dy. CIT (2018) 194 TTJ 69/ 167 DTR 281 (Hyd.)(Trib.)
S. 254(1) :Appellate Tribunal – Additional ground – validity of the assessment can be challenged at any time as it goes to the root of the matter and is a legal issue.