(1.) WHETHER the Income-tax Appellate Tribunal could entertained a new plea/ground though on the same subject-matter which did not arise out of the orders passed by the Revenue forums below, is the interesting question raised in this reference.
(2.) THE Revenue has submitted a statement of case for the opinion of this court on the following two questions :
(3.) THE assessee thereafter sought a reference of the abovestated questions and that is how we are seized of the matter.