Held that Commissioner (Appeals) cannot introduce new source of income. Assessment to be confined to items of income which were subject matter of original assessment. (AY.2007-08 to 2013-14).
N. R. Agarwal Industries Ltd. v. ACIT (2021)91 ITR 503 (Surat) (Trib.)
S. 251 : Appeal-Commissioner (Appeals)-Power of enhancement of income-Commissioner (Appeals) cannot introduce new source of income-Assessment to be confined to items of income which were subject matter of original assessment. [S.. 251(1)(a)]