Principle of grossing up of inome applicable as per S.9(2) Explantion 2 was not agitated before lower authorities , hence cannot be raised for first time before Court. (AY. 2002-03, 2003-04)
TVS Motor Co. Ltd. v. ITO (2018) 258 Taxman 77/170 DTR 15 / 304 CTR 853 / ( 2019) 413 ITR 171 (Mad.)(HC)
S. 260A : Appeal-High Court – Issue not raised and adjudicated by lower authorities – Cannot be permitted to be raised for first time in appeal to High Court .[ S.195A, 201(1) 201(1A) ]