Tribunal jurisdiction is confined to issues arising from the record; new tax liability questions cannot be introduced on appeal.

The Tribunal cannot decide a tax liability issue that did not arise from the assessment order or the first appellate order and was never part of the record below. Here, the lower authorities dealt only with tapioca simpliciter and its claimed exemption, while liability on tapioca chips was neither raised by the assessing authority nor argued before the appellate authority. Because the question of tapioca chips was outside the scope of the proceedings, the Tribunal travelled beyond the issues properly before it. The discussion on whether tapioca chips retained the character of tapioca could not cure that jurisdictional defect.

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Issues: Whether the Tribunal could decide the liability of tapioca chips to purchase tax when that question did not arise from the assessment order or the first appellate order.

Analysis: The assessment order and the first appellate order dealt only with tapioca simpliciter and with the question whether tapioca was exempt from tax for the relevant assessment year. The issue of tapioca chips was not raised by the assessing authority, was not urged before the appellate authority, and did not emerge from the factual matrix on record. The Tribunal therefore proceeded on an issue that was not in existence before the lower authorities. Since the matter had not arisen for adjudication below, the Tribunal's discussion on whether tapioca chips retained the character of tapioca could not alter the basic position that the question itself was outside the scope of the proceedings.

Conclusion: The Tribunal erred in travelling beyond the issues arising from the record, and the revision had to fail.

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