Question couldn't be raised for first time before HC if same wasn't framed during appellate proceedings

IT: Where in course of appellate proceedings, Tribunal held that income earned by assessee from sale of shares held for more than one year was taxable as long-term capital gain, since there was no question framed relating to applicability of Explanation to section 73 in course of appellate proceedings, said question could not be raised for first time in proceedings pending before High Court

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