Held that the additional ground was purely a legal ground, not requiring examination of any new facts hence admitted. followed  National Thermal Power Co. L td. v. CIT (1998) 229 ITR 383 (SC)  Since the claim of the assessee had been raised for the first time before the Tribunal and since the Assessing Officer did not have occasion to examine it, this issue is t be restored to the Assessing Officer for examination in the light of contentions raised by the assessee and in accordance with law. (AY.2017-18, 2018-19)