JUDGMENT

K.N. SINGH, J. :— The appellant is a Government Corporation engaged in jute industry. It was assessed to income tax for the, assessment year 1974-75 by the Income-tax Officer. The assessee preferred appeal before the Appellate Assistant Commissioner. During the hearing of the appeal, the assessee raised an additional ground claiming deduction of Rs. 11,54,995/- on the ground of liability of Purchase-tax. The assessee claimed that in view of the decision of this Court in Kedarnath Jute Company Ltd. v. Commr. of Income-tax, 82 ITR 363, the aforesaid amount being tax liability. should be deducted from its income for purposes of charging tax. The Appellate Assistant Commissioner permitted the assessee to raise the additional ground and after hearing the Income-tax Officer, he accepted the assessees claim and allowed deduction of Rs. 11,54,995/- in computing, the total income of the assessee for the assessment year 1974-75. The Revenue preferred appeal before the Income-tax Appellate Tribunal. The Tribunal held that the Appellate Assistant Commissioner had no jurisdiction to entertain an additional ground or to grant relief to the assessee on a ground which had not been raised