While drafting the appeal, a lot of care should be taken, so as to include all the grounds, therein. Though the Commissioner of Income-tax (Appeals) or, the Appellate Tribunal has the powers to entertain additional grounds, the same can be raised, only, before the disposal of the appeal and, with the permission of the appellate authority. For admission of the additional grounds, the person must have adequate reasons for not raising the ground at the time of filing the appeal.