Dismissing the petition the Court, power of an appellate authority under Act is co-terminus with that of an Assessing Officer and hence any lacunae in procedure can well be corrected even at that stage.  The assessee challenged impugned assessment order on ground that order of assessment had travelled beyond scope of show-cause notice as said order rejected assessees entitlement to carry-forward long-term capital loss even when such a proposal did not form part of pre-assessment show-cause notices, since assessee had already challenged assessment order by way of a statutory appeal and there being no extraordinary circumstances in instant case to intervene in impugned order, it was to be left to assessee to pursue. Court observed that  it is left to the assessee to pursue the statutory appeal filled by it. (AY. 2021-22)