C&C Construction Pvt Ltd vs. CIT (Delhi High Court)

S. 260A: High Court has no power to consider issue not raised before Tribunal. The assessee filed an appeal before the Tribunal in which it argued that it had constructed a “temporary construction” which was eligible for 100% depreciation. This was rejected by the Tribunal on the basis that the construction was permanent. Before the High Court, the assessee argued for the first time that the expenditure was “revenue” in nature and admissible as business expenditure. HELD not permitting the assessee to raise the plea.