S. 254(1) : Appellate Tribunal –Powers- Deemed dividend –Buy back of shares -Tribunal has power to give directions for fresh enquiry into aspects of subject matter of appeal filed before it either suo motu or on any grounds raised by either party to appeal which have not been investigated or enquired into by lower authorities earlier and which may result in enhancement of tax liability of assessee – Direction is held to be valid .[ S.2(22) ( e ),115QA ]