- (1.) This appeal is directed by the assessee against the order of the Commissioner (Appeals), dated 27-11-1997.
(2.) Various grounds of appeal have been raised by the assessee against the assessment order passed by the assessing officer under section 158BD of the Income Tax Act. However, assessee has raised additional grounds of appeal and has requested that since the additional ground of appeal requires no verification of facts, it is purely legal, the same should be admitted.
(3.) The following additional grounds of appeal have been raised: 1."Because the assessment order, dated 27-11-1997, is wholly illegal, as being outside the purview and scope of section 158BD (Chapter XIV-B) of the Income Tax Act, 1961. 2. Because there existed no material/information which could lead the assessing officer to have the requisite satisfaction so as to confer jurisdiction on him to initiate proceedings under section 158BD in the case of the appellant.";