Additional grounds on new claims must be decided on merits; unresolved turnover issues justified remand for fresh adjudication.

Admitted additional grounds raising new claims not examined in the assessment must be decided on their own merits and cannot be rejected merely by applying consistency with earlier years. Where the appellate authority has not addressed all issues raised, including turnover exclusions and related attribution questions, and the relevant material was not before the Assessing Officer, the proper course is remand for fresh adjudication after giving the assessee an opportunity of hearing. The matter was therefore restored for reconsideration on the factual record.

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Issues: Whether the appellate authority was justified in rejecting the assessee's additional grounds on the basis of consistency without deciding them on merits, and whether the matter required remand for fresh adjudication.

Analysis: The additional grounds raised new claims that had not been examined in the assessment proceedings. Once such grounds were admitted, they required adjudication on their own merits and could not be disposed of merely by invoking consistency with earlier years. The appellate authority had also not decided all the issues raised, including the exclusion of certain turnover components and related attribution questions. Since material on these new claims was not available before the Assessing Officer and the controversy needed factual examination, the proper course was to restore the matter for fresh consideration after granting the assessee an opportunity of hearing.

Conclusion: The rejection of the additional grounds on the basis of consistency was not sustained, and the matter was remanded to the Assessing Officer for fresh adjudication.

Ratio Decidendi: Where an assessee raises admitted additional grounds involving new claims not examined in assessment, the appellate authority must decide them on merits and may remit the matter for fresh consideration if the relevant material was not before the Assessing Officer.

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