ORDER

1. The assessee carries on the business inter alia, of construction, generation, operation and maintenance of thermal power stations and associated transmission network.

2. During the Assessment Year 1978-79 the assessee had deposited its funds which were not immediately required, on short-term deposits with banks. Interest received on such deposits during the previous year relevant to the Assessment Year 1978-79 amounted to Rs. 22,84,994. This was offered by the assessee for tax assessment and the assessment was completed on that basis. Before the Commissioner of Income Tax (Appeals) a number of grounds were taken by the assessee challenging the assessment. However, the inclusion of this amount of Rs. 22,84,994 was neither challenged by the assessee nor considered by the Commissioner of Income Tax (Appeals). From the order of the Commissioner of Income Tax (Appeals) the assessee filed an appeal before the Tribunal. The inclusion of the said amount of Rs. 22,84,994 was not objected to even in the grounds of appeal as originally filed before the Tribunal. However, by a forwarding letter dated 16-7-1983 the following additional grounds were sought to be raised by the assessee :