Court held that where questions are raised regarding jurisdiction or limitation if the grounds are valid , the mere fact that it was not raised before the AO or at the first instance cannot preclude the assessee from raising it in appeal or even before the Court . (AY. 2000 – 01 to 2006 – 07)
K. V. Abdul Azeez v. CIT (2018) 404 ITR 288/ 253 Taxman 210 / 168 DTR 74/ 204 CTR 801(Ker)(HC)
S. 260A : Appeal – High Court – Jurisdiction and limitation issue can be raised for the first time in appeal [ S.153C, 253 ]