Allowing the appeal of the assessee the Court held that ; the use of the word “thereon” in section 254(1) of the Income-tax Act, 1961 is important and it reflects that the Tribunal has to confine itself to the questions which arise or are subject matter in the appeal and it cannot travel beyond that. The power to pass such order as the Tribunal thinks fit can be exercised only in relation to the matter that arises in the appeal and it is not open to the Tribunal to adjudicate any other question or issue, which is not in dispute and which is not the subject matter of the dispute in appeal. Accordingly, when the amounts could not have been added under section 68 , the Tribunal was not competent to make the addition under section 69A .The order of the Tribunal was vitiated in law-Matter remanded to the Tribunal. (2001-02)