24 April 2013
Statement of Facts are better known to you then any of us. . What ever legal proceeding narrated in the Assessment Order can be part of the Statement of Facts, depending upon the issue which you want to raise in the appeal. . A Fact is like an event taking place. Suppose the case has been selected for scrutiny (FACT)and the learned ITO had made/ wrongly made /certain additions (FACT). There may be many facts but for your case you can find out the facts from the assessment order itself. . Your logical arguments , reasoning, case laws, supportive submissions etc.are covered under the Grounds of Appeal. .