Appellate jurisdiction is confined to pleaded grounds; interest liability cannot be decided without a valid ground of appeal.

An appellate authority cannot determine liability or compute interest on a sales tax matter when that issue was not raised in the memorandum of appeal and no additional ground was permitted or argued. The Tribunal in the cited matter was confined to the challenge on taxable turnover and had no jurisdiction to travel beyond the issues actually placed before it. Its modification of the interest levy was therefore treated as unjustified and liable to be set aside. The governing principle is that an appellate forum must stay within the grounds properly before it.

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Issues: Whether the Tribunal could determine the liability and calculation of interest under the sales tax law when the Commissioner's appeal did not raise any grievance on that point.

Analysis: The appeal before the Tribunal was confined to the rejection of taxable turnover. No ground assailing the charging or computation of interest was taken in the memorandum of appeal, no additional ground was permitted, and none was raised at the hearing. In such circumstances, the Tribunal could not travel beyond the issues actually placed before it and could not adjudicate upon the question of interest.

Conclusion: The Tribunal acted without justification in modifying the levy of interest, and that part of its order was liable to be set aside.

Ratio Decidendi: An appellate authority cannot decide a matter not raised in the appeal unless a proper additional ground is permitted and adjudicated.

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