https://www.taxtmi.com/caselaws?id=449335 The ITAT Delhi ruled in favor of the assessee regarding CIT(A)'s power of enhancement under sections 250 and 251. The AO had made an addition under section 68, but CIT(A) changed it to section 69A without proper examination. The tribunal held that CIT(A) misdirected himself by relying on Kanpur Coal Syndicate case, noting that the Delhi HC in Sardari Lal Co. established that first appellate authority cannot consider new sources of income given specific provisions under sections 147/148 and 263. The CIT(A)'s enhancement was deemed improper as the AO had already thoroughly examined the issue under section 68. en-us Wed, 07 Feb 2024 00:00:00 +0530 Fri, 09 Feb 2024 10:17:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449335 The ITAT Delhi ruled in favor of the assessee regarding CIT(A)'s power of enhancement under sections 250 and 251. The AO had made an addition under section 68, but CIT(A) changed it to section 69A without proper examination. The tribunal held that CIT(A) misdirected himself by relying on Kanpur Coal Syndicate case, noting that the Delhi HC in Sardari Lal Co. established that first appellate authority cannot consider new sources of income given specific provisions under sections 147/148 and 263. The CIT(A)'s enhancement was deemed improper as the AO had already thoroughly examined the issue under section 68. Case-Laws Income Tax Wed, 07 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449335