https://www.taxtmi.com/caselaws?id=6523 Appellate relief under section 251(1)(a) of the Income-tax Act, 1961 is limited to matters that were part of the subject-matter of assessment before the Income-tax Officer. Mere taxation of a receipt does not mean exemption from that receipt was considered, and a fresh claim cannot be entertained unless the Officer had applied his mind to the item's taxability or non-taxability. On the stated facts, no claim for exemption under section 84 had been made before the Income-tax Officer and no supporting material existed at that stage, so the appellate authority could not grant the relief and the Tribunal was not justified in directing it. en-us Tue, 08 Nov 1977 00:00:00 +0530 Tue, 03 Mar 2015 12:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6523 Appellate relief under section 251(1)(a) of the Income-tax Act, 1961 is limited to matters that were part of the subject-matter of assessment before the Income-tax Officer. Mere taxation of a receipt does not mean exemption from that receipt was considered, and a fresh claim cannot be entertained unless the Officer had applied his mind to the item's taxability or non-taxability. On the stated facts, no claim for exemption under section 84 had been made before the Income-tax Officer and no supporting material existed at that stage, so the appellate authority could not grant the relief and the Tribunal was not justified in directing it. Case-Laws Income Tax Tue, 08 Nov 1977 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6523