ITATs can allow ground which was not taken before CIT(A) & Assessing Officer

PCIT Vs Eversafe Securities (Calcutta High Court) Whether ITAT has the power to entertain additional ground without recording reasons and without following Rule 46A of the Income-tax rules, 1962 and whether jurisdictional issue relating to non issuance of notice u/s 143(2) can be raised at any time? The Division Bench of Calcutta High Court in this case was dealing with a case where the issue regarding non issuance of notice u/s 143(2) by the jurisdictional AO (which was raised for the first time before ITAT ) was allowed by the ITAT and on appeal by the department, the Division bench held tha...