Appellate jurisdiction is confined to the assessment year under appeal and cannot decide taxability for another year.

The appellate authority's jurisdiction was confined to the assessment year under appeal and the matters required to be decided for that year. Once it was found that the sum did not relate to the year in appeal, it could be deleted from that assessment; a further finding that the same amount was undisclosed income of another year went beyond jurisdiction. The authority was therefore not competent to hold that the amount was assessable in a different assessment year.

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Issues: Whether the Appellate Assistant Commissioner had jurisdiction, while dealing with the assessment for one assessment year, to record a finding that the same sum was assessable in a different assessment year.

Analysis: The jurisdiction of the appellate authority was confined to the assessment year under appeal and to the matters required to be decided in relation to that year. Once it was found that the sum in question did not pertain to the year under appeal, it was sufficient to delete it from that assessment. A further finding that the same amount represented undisclosed income of another year travelled beyond the scope of the appeal and was outside jurisdiction.

Conclusion: The Appellate Assistant Commissioner was not competent to give a finding that the sum of Rs. 1,00,000 was assessable in the year 1956-57.

Ratio Decidendi: The appellate authority under the income-tax law cannot make a finding on assessability for a year not before it; its jurisdiction is confined to the assessment year under appeal.

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