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2022 (1) TMI 1189 - AT - Income TaxAdmission of additional grounds - Addition made under MAT provisions of the Act consisting of profit on sale of vessels and disallowance under section 14A - HELD THAT:- These were not challenged before the Ld. First Appellate Authority in quantum proceedings, and therefore the Ld. Assessing Officer did not give any relief on said additions. The additions under MAT provisions have been raised for first time before us. The assessee in ground No. 2 (two) of the appeal has raised the issue that Ld. CIT(A) has not considered those ground as additional ground and not considered the decision of the Hon’ble Supreme Court in the case of National Thermal Power Company Ltd Vs CIT [1996 (12) TMI 7 - SUPREME COURT]. The Ld. Counsel accordingly prayed orally for admitting the grounds challenging the additions as additional grounds. The Ld. departmental representative did not object for the oral plea of the assessee for admitting those grounds as additional ground. The assessee can raise legal grounds at any stage of the appellate proceedings. In view of above facts and circumstances and in the interest of substantial justice, we find it appropriate to admit the grounds related to additions made under MAT provisions as additional ground and remit the issue back to the file of the Ld CIT(A) for adjudication afresh- Appeal filed by the assessee is allowed for statistical purposes.
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