4.4. On the contrary, the ld. D/R opposed the submissions and placed reliance on
the another Coordinate Bench decision rendered in the case of late Iqbal Hussain vs.
ITO (2007) 111 TTJ 717 (All.). The ld. D/R submitted that this ground was not
taken before the ld. CIT (A) and has not even taken before this Tribunal.