https://www.taxtmi.com/caselaws?id=21388 HC held that the Appellate Tribunal has jurisdiction to permit additional grounds in appeals concerning deductibility of amounts transferred to reserves arising from tax proceedings (including loss on destruction of stock). While appellate authorities cannot devise new sources of income, they may consider the whole record to determine correct tax liability and, where the Department files an appeal or cross-objections, can enhance the assessee's tax liability if warranted. The Tribunal has discretion to allow new grounds so long as they arise from the subject matter of the proceedings. en-us Thu, 30 Apr 1992 00:00:00 +0530 Fri, 24 Oct 2025 15:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=21388 HC held that the Appellate Tribunal has jurisdiction to permit additional grounds in appeals concerning deductibility of amounts transferred to reserves arising from tax proceedings (including loss on destruction of stock). While appellate authorities cannot devise new sources of income, they may consider the whole record to determine correct tax liability and, where the Department files an appeal or cross-objections, can enhance the assessee's tax liability if warranted. The Tribunal has discretion to allow new grounds so long as they arise from the subject matter of the proceedings. Case-Laws Income Tax Thu, 30 Apr 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=21388