Matter not raised before tribunal cannot be raised before High Court

Brief of the Case Punjab & Haryana High Court held In the case of M/s Maken Cement Industries vs. CIT that it is settled principle that the substantial question of law would only be based on the documents which were before the authorities below and also which were subject matter of consideration before the Tribunal. Once the stand was contrary before the Assessing Authority at the initial stage, the argument which is now sought to be raised cannot be addressed before the Court. Facts of the Case In this case assessee was following mercantile system of accounting. The question was raised by...