Income Tax Act, 1967.

Provision as to appeals.

417.—Whenever an appeal is made against an assessment, the appellant shall in the notice of appeal specify the grounds of the appeal, but this subsection shall not preclude the Special Commissioners from allowing the appellant on the hearing of the appeal to go into any ground of appeal which was not specified in the notice of appeal and the omission of which from such notice was in the opinion of the Special Commissioners not wilful or unreasonable.