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1972 (8) TMI 9 - MADRAS HIGH COURT
Tribunal cannot deal with a subject-matter which has been considered by the assessing authority but not challenged before the Appellate Assistant Commissioner by the assessee, in an appeal before the Tribunal in relation to other items of dispute. It will be a fortiori a case where an assessee did not seek to challenge a particular item before the Appellate Assistant Commissioner or before the Tribunal at the original stage but seeks to challenge the same at a later stage by way of additional grounds. We, therefore, hold that the Tribunal is justified in refusing to excuse the delay in filing the additional grounds of appeal dealing with a new subject-matter