Admission of additional ground and evidence led to remand for fresh consideration of the agricultural income dispute.

An additional ground may be admitted in appellate proceedings when it is purely legal or computational and does not require fresh factual inquiry. Additional evidence may also be admitted where it directly bears on the disputed issue, arose after the impugned order, and the party shows sufficient cause for earlier non-production. Applying these principles, the appellate authority admitted both the additional ground and the additional evidence because they were relevant to the agricultural income dispute, and then remanded the matter to the Assessing Officer for fresh adjudication after giving proper hearing.

---

---

Issues: Whether the additional ground and additional evidence could be admitted and whether the matter should be remanded for fresh adjudication.

Analysis: The additional ground was treated as a legal and computational issue that did not require fresh factual investigation, and was therefore admitted under the appellate rules. The additional evidence was also admitted because it had a direct bearing on the genuineness of the agricultural income claim, had come into existence after the impugned order, and the assessee was shown to have been prevented by sufficient cause from producing it earlier. Since the agricultural income dispute required reconsideration in the light of the additional material, the entire controversy was sent back to the Assessing Officer for reexamination after giving proper opportunity of hearing.

Conclusion: The additional ground and additional evidence were admitted, and the assessment issues were remanded to the Assessing Officer for fresh consideration.

Ratio Decidendi: Where an additional ground is purely legal or computational and additional evidence is relevant to the controversy with sufficient cause for earlier non-production, the appellate authority may admit them and remit the matter for reconsideration on the merits.

---