Law:

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Section 260A of the Income-tax Act, 1961 - High court - Appeal to others Where on appeal, appellant contended that search party in course of search had in their possession a blank panchnama and filled same at time of search which was not valid in law, but it was found that no such allegation was even raised before Tribunal nor was any material placed before Tribunal in support of said submission, in absence of any such point having been raised before Tribunal, it was not now open to appellant to raise such a grievance for first time in instant appeal [Block period 1989-90 to 1999-2000] [In favour of revenue] Anjuga Chit Fund (P.) Ltd. v. Dy. CIT [2009] 318 ITR 121 (Mad.) Where on appeal, the appellant contended that the search party, in the course of the search, had in their possession a blank panchnama and filled the same at the time of the search which was not valid in law, but it was found that no such allegation was even raised before the Tribunal nor was any materials placed before the Tribunal in support of the said submission, in the absence of any such point having been raised before the Tribunal, it was not now open to the appellant to raise such a grievance for the first time in the instant appeal. S. Sridhar for the Appellant. K. Subramaniam for the Respondent. JUDGMENT F.M. Ibrahim Kalifulla, J. - At the foremost, Mr. S. Sridhar, learned counsel appearing for the appellant, raised the following substantial question of…

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