Dismissing the appeal of the assessee the Court held that ; 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. Said directions could not be said to be per se amounting to taxability of said payout by assessee as ‘Dividend’ but same would depend upon nature of enquiry to be conducted by assessing authority and findings arrived at in pursuance of said direction. Accordingly the Tribunal was right and within its jurisdiction in directing examination of fair market value of shares bought-back by it during previous year relevant, which could have an implication of taxability under section 2(22)(e) of the Act . (AY. 2011-12)