Held that Commissioner (Appeals) has no jurisdiction to travel beyond record when the issue was regarding addition of cash credits, the Commissioner (Appeals) cannot enhance and make addition on account of estimate of commission at 2 Per Cent. without issuing show cause notice, which is gross violation of principle of natural justice (AY.2012-13 to 2014-15)
ITO v. Angel Cement Pvt. Ltd. (2021)88 ITR 616 (Delhi)(Trib.)
S. 251 : Appeal-Commissioner (Appeals)-Power of enhancement-No jurisdiction to travel beyond record-Appeal against cash credits-Enhancement cannot be made for making estimate commission of 2 Per Cent of commission. [S. 68, 251(1)(a)]