(2)The [Commissioner (Appeals)] [ Substituted by Act 22 of 1995, Section 50, for " Collector (Appeals)" (w.e.f. 26-5-1995). ] 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 [Commissioner (Appeals)] [ Substituted by Act 22 of 1995, Section 50, for " Collector (Appeals)" (w.e.f. 26-5-1995). ] is satisfied that the omission of that ground from the grounds of appeal was not wilful or unreasonable.
