The Tribunal also held that the Departmental representative is not permitted to set up an altogether a new case with respect to the applicability of section. 17(3)(iii) of the Act. Referred, Mahindra and Mahindra Ltd v. Dy. CIT (2009) 313 ITR 263 (A.T)(Trib)(SB)(AY.2009-10)
ITO v. Avirook Sen (2024)111 ITR 78 (SN)/ 230 TTJ 132/ (Delhi)(Trib)
S. 254(1) : Appellate Tribunal-Powers-Departmental representative is not permitted to set up an altogether a new case.[S. 15, 17(3)(i)]