Appellate enhancement is confined to income sources examined in...

Appellate enhancement is confined to income sources examined in assessment and cannot introduce sale consideration as a new taxable source where only related expenditure was scrutinised. Advance rental receipts already offered in later years are not taxable again absent accrual in the relevant year, preventing double taxation. Recorded bank credits, loans and advances supported by ledgers, confirmations and banking evidence cannot be treated as unexplained without adverse material. Likewise, no unexplained-investment addition arises for shareholdings acquired in earlier years, while documentary proof of disclosed cash sources and individual-to-HUF transfers shifts the evidentiary burden to the Revenue.