ITAT refers matter back to AO as Assessee challenged legal grounds 1st time before ITAT

Smt. Tajinder Pal Kaur Vs ITO (ITAT Amritsar) The assessee has challenged both the legal and factual grounds before the Bench. But during the appeal proceedings before the ld. CIT(A), the assessee had not challenged the legal grounds so there are first time challenging the issue before the ITAT. So, the entire legal ground was setting aside before the ld.AO for its verification. In the factual ground the grievance of the revenue that the acceptance of the instrument related to transfer of the property like agreement and power of attorney was in question. In the hearing before bench, the assess...