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 all

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