https://www.taxtmi.com/caselaws?id=14490 The dominant issue was whether the CIT(A) could consider statutory certificates (Forms 10C and 10D) for deduction under s. 80HH despite non-filing with the return as mandated by s. 80HH(5). Interpreting s. 251(1)(a), the HC held that the CIT(A)'s powers are akin to reassessment and require full examination of the case while confirming, reducing, or enhancing assessment; tax appeals are not strictly adversarial and must ensure assessment according to law. Consequently, the CIT(A) ought to have evaluated the certificates (and related material) or remanded for proper assessment. The Tribunal's view was upheld, and the reference was answered in favour of the assessee against the Revenue. en-us Mon, 09 Aug 1999 00:00:00 +0530 Thu, 01 Jan 2026 10:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=14490 The dominant issue was whether the CIT(A) could consider statutory certificates (Forms 10C and 10D) for deduction under s. 80HH despite non-filing with the return as mandated by s. 80HH(5). Interpreting s. 251(1)(a), the HC held that the CIT(A)'s powers are akin to reassessment and require full examination of the case while confirming, reducing, or enhancing assessment; tax appeals are not strictly adversarial and must ensure assessment according to law. Consequently, the CIT(A) ought to have evaluated the certificates (and related material) or remanded for proper assessment. The Tribunal's view was upheld, and the reference was answered in favour of the assessee against the Revenue. Case-Laws Income Tax Mon, 09 Aug 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=14490