Assessment u/s 143(3) was completed by making addition on account of disallowance u/s 14A. On Appeal the entire disallowance was deleted. However Commissioner (Appeals) by invoking sec 251(1)(a), enhanced the income by disallowing interest u/s 36(1)(iii) on the ground that was totally different from the ground in show cause notice.  On appeal the Tribunal held that the enhancement was without jurisdiction and contrary to principles of natural justice, as no reasonable opportunity was given to assessee to rebut the reason because of which such enhancement was made. Tribunal also held that while taxing the Income from a new source which was not the subject matter of Assessment or has not been considered by A.O, the right manner to tax such new source would be by invoking section 147,148 or sec 263, since there is no such power available to commissioner.  Followed  CIT v. Raj Bhadur Harduty Motilal Chmaria (1967) 66 ITR 443(SC), CIT v. Sardari lal & Co (2001) 251 ITR 864 (FB)(Delhi) (HC)  (AY. 2013-14)