Dismissing the appeal of the assessee the Court held that; in fact, on going through the orders passed by the authorities below, the “matching concept” was never even argued or raised before them. Therefore, this argument can never give rise to a substantial question of law in the facts and circumstances of the present case. (AY. 2002-03, 2003-04)
L & T Finance Ltd. v. Dy. CIT (2018) 258 Taxman 282 (Bom.)(HC)
S. 260A : Appeal – High Court – Question of matching concept which was never argued before the Tribunal nor raised before the High Court, cannot be argued first time before the High Court. [S.28(i)]