https://www.taxtmi.com/caselaws?id=166248 Tribunal appellate powers under section 33(4) extend to admitting fresh evidence and deciding an assessment on merits, provided both parties receive an opportunity to be heard. The subject matter remains the correctness of the assessment and is not confined to grounds stated in the appeal memorandum. For unexplained cash receipts, the assessee bears the burden of proving the source and nature of the funds. Where the explanation is rejected as unreliable and surrounding circumstances support an inference of concealment, the resulting factual finding is sustainable if supported by material and does not raise a question of law. en-us Wed, 01 Sep 1954 00:00:00 +0530 Fri, 05 Sep 2014 14:53:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=166248 Tribunal appellate powers under section 33(4) extend to admitting fresh evidence and deciding an assessment on merits, provided both parties receive an opportunity to be heard. The subject matter remains the correctness of the assessment and is not confined to grounds stated in the appeal memorandum. For unexplained cash receipts, the assessee bears the burden of proving the source and nature of the funds. Where the explanation is rejected as unreliable and surrounding circumstances support an inference of concealment, the resulting factual finding is sustainable if supported by material and does not raise a question of law. Case-Laws Income Tax Wed, 01 Sep 1954 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=166248