The assessee, an educational institution, sought exemption under section 10(23C) by raising an additional ground before the Commissioner (Appeals) during reassessment proceedings, though no such claim had been made in the original return. The Tribunal held that reassessment proceedings are intended to examine escaped income and do not permit an assessee to seek review of concluded matters or raise a fresh claim unrelated to the reasons recorded for reopening. The Commissioner (Appeals) exceeded his jurisdiction in entertaining the new claim. However, the matter was restored to decide the appeal on the merits of the additions made by the Assessing Officer. (AY. 2009-10).