National Thermal Power Co. Ltd. vs Commissioner Of Income Tax on 4 December, 1996
3. Since the additional ground involves a legal issue and is
connected with the first main issue espoused in the memorandum
of appeal, and that no further verification of fresh facts is
warranted, we admit the same in the light of judgment of the
Hon'ble Supreme Court in National Thermal Power Company Ltd.
Vs. CIT (1998) 229 ITR 383 (SC) wherein the Hon'ble Apex Court
3
ITA No.1736/PUN/2018 &
1763/PUN/2019
Goodyear South Asia Tyres Pvt. Ltd.,
has observed that "the purpose of the assessment proceedings
before the taxing authorities is to assess correctly the tax liability
of an assessee in accordance with law". The additional ground will
be dealt with at appropriate stage.