Rule 10 - Grounds which may be taken in appeal. - Customs, Excise and Service Tax Appellate Tribunal (Procedure) Rules, 1982

RULE 10. Grounds which may be taken in appeal. — The appellant shall not, except by leave of the Tribunal, urge or be heard in support of any grounds not set forth in the memorandum of appeal, but the Tribunal, in deciding the appeal, shall not be confined to the grounds set forth in the memorandum of appeal or those taken by leave of the Tribunal under these rules: Provided that the Tribunal shall not rest its decision on any other grounds unless the party who may be affected thereby has had a sufficient opportunity of being heard on that ground.