Section 80IA of the Income Tax Act, 1961 — Deduction — the question whether or not to allow an additional ground to be raised before the appellate authority is to be deicded by the appellate authority in exercise of its discretion considering the facts and circumstances of the case before it. Where only a pure question of law arises from facts which are already on record there is no reason why the appellate authority should not consider the question of law so as to determine the correct tax liability of an assessee in accordance with law. There was nothing on record to indicate the reason which prevented the assessee from raising a claim for deduction under Section 80IA during the proceedings before the AO and the Commissioner (appeals), thus, the decision of the Tribunal that the new ground urged could not be allowed to be raised was justified — Ultra Tech cement Ltd. vs. Additional Commissioner of Income tax [2018] 408 ITR 500 (Bombay)