Ntpc Ltd. vs Commissioner Of Income Tax-V on 16 April, 2014
3. Addressing the additional ground, it was his submission that it was a
legal ground which had not been raised before the CIT(A) or the ITAT
originally. It was his argument that raising of the same was permissible as no
verification of facts was required. Referring to the impugned order, it was his
submission that arguments to the said effect have been advanced before the
CIT(A) in both the appeals presumably in the absence of a ground it was not
adjudicated upon. Relying upon the decision of the Supreme Court in NTPC
Vs CIT 229 ITR 383 (S.C.)