Limited remand confines appellate jurisdiction to the issue restored and bars a new limitation challenge to the assessment.

A limited appellate remand confines the lower authority's jurisdiction to the specific issue restored for fresh consideration, and it cannot be enlarged by introducing an unrelated challenge to the assessment's validity on limitation. Here, the Tribunal had remanded only the assessee's claim for deduction of leave with wages, so the appellate authority was not required to reopen the assessment as a whole or admit a new limitation ground. The additional ground was therefore rightly refused, and the limitation challenge failed because it fell outside the scope of the remand.

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Issues: Whether an additional ground challenging the legality of the assessment on limitation could be admitted when the earlier remand was confined to a single specified issue.

Analysis: The remand by the Tribunal was limited to the assessee's claim for deduction of leave with wages and restored only that issue for fresh disposal. In such confined proceedings, the appellate authority was not required to reopen the whole assessment or enlarge the scope of enquiry to a new challenge against the validity of the assessment on limitation. Authorities on limited remand supported the view that proceedings remain restricted to the point remanded and do not permit introduction of an unrelated additional ground.

Conclusion: The additional ground was rightly refused and the assessee's contention on limitation was rejected.

Final Conclusion: The appeal failed because the remand was restricted to one issue and did not permit a fresh challenge to the assessment as a whole.

Ratio Decidendi: Where an appellate remand is confined to a specific issue, the lower authority's jurisdiction on remand is limited to that issue alone and cannot be expanded by a new ground attacking the assessment on an independent basis.

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