1980 (9) TMI 74 - DELHI HIGH COURT

Extract:
.......ment with the view taken by the Tribunal that such a point cannot be raised and should not be permitted to be raised when not raised either before the ITO or the AAC. We would, accordingly, answer the question referred to us in the affirmative, in favour of the assessee and against the department. The assessee will get costs. Counsel s fee Rs. 500.