Appellate jurisdiction cannot extend beyond the grounds raised; unrelated valuation and penalty findings were improperly reopened.

An appellate authority must remain confined to the grounds actually raised in the appeal and cannot travel beyond the disputed issue to reopen unrelated findings. Where the matter before it concerned only refund of sale proceeds, it had no jurisdiction to reassess separate issues such as valuation and penalty that were not under challenge. By expanding the scope of review and directing de novo adjudication, the authority acted beyond its appellate jurisdiction. The impugned order was therefore unsustainable and was set aside.

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Issues: Whether the Collector (Appeals) exceeded the scope of the appeal by going beyond the grounds raised and remanding the matter for de novo adjudication.

Analysis: The appellate authority was required to confine itself to the question actually raised before it, namely the refund of the sale proceeds. It could not reassess unrelated findings on valuation and penalty when those issues were not in appeal. By undertaking a broader examination and ordering a de novo decision, it acted beyond its jurisdiction.

Conclusion: The impugned order could not be sustained and was set aside.

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