Tribunal held that issue of specific charge was not raised in original proceedings , accordingly the  issue which did not emanate either from CIT(A) in first round of appeal or from order of Tribunal dt. 10.03.2011, same cannot be agitated in miscellaneous  application matter  in which matter was remanded to record of AO.  Scope of miscellaneous  application u/s 254(2) was very limited and circumscribed and parties to appeal cannot be allowed to raise any issue in proceedings u/s 254(2) to set up a new case not arising from proceedings completed till then. Accordingly when this issue was neither arisen from order passed by AO or CIT(A) originally nor from order passed by Tribunal  , accordingly issue cannot be raised in appeal filed against order passed in remand proceedings.  ( AY. 2005 -06)