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TMI Blog2015 (2) TMI 665X X X X Extracts X X X X X X X X Extracts X X X X ..... o consideration as part of the grounds already raised by the Revenue. Consequently, the questions of law framed by the Tribunal are answered in affirmative holding that the Tribunal was rightly held in ground Nos.3 and 4 are wide enough to include additional grounds regarding weighted deduction, which are clarificatory in nature. - Decided in favour of revenue. - ITR No. 66 of 1994 - - - Dated:- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s to be raised in as much as the additional grounds were held to be clarificatory in nature and by way of amplification of the existing grounds. 2. Whether on the facts and in the circumstances of the case, the Tribunal was right in law in allowing two additional grounds to be raised by the appellant without adequately explaining the delay in raising those grounds. We have gone through the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d the following additional two grounds on 20.11.1990:- 1. That on the facts and in the circumstances of the case, the Ld. CIT (A) has erred in allowing weighter deduction under Section 35-B on the expenses incurred on sea freight ₹ 12,65,266/-, freight and other charges from Rajpura to port ₹ 6,89,879/- and insurance charges ₹ 1,46,109/-. 2. That on the facts and in the ci ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eady raised by the Revenue. Consequently, the questions of law framed by the Tribunal are answered in affirmative holding that the Tribunal was rightly held in ground Nos.3 and 4 are wide enough to include additional grounds, which are clarificatory in nature. As per the office report, the record of ITC No.79 of 1994 has been burnt arising out of the same order of the Tribunal. Therefore, the s ..... X X X X Extracts X X X X X X X X Extracts X X X X
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