Section 55B(5) in Income-Tax (Certificate Proceedings) Rules, 1962
(5)The [Chief Commissioner or Commissioner] [Substitued for the words Tax Recovery Commissioner by the Income-tax (Certificate Proceedings) (Second Amendment) Rules, 1990] may, at the hearing of an appeal, allow the appellant to go into any ground of appeal not specified in the grounds of appeal, if the [Chief Commissioner or Commissioner] [Substitued for the words Tax Recovery Commissioner by the Income-tax (Certificate Proceedings) (Second Amendment) Rules, 1990] is satisfied that the omission of that ground from the form of appeal was not wilful or unreasonable.
