https://www.taxtmi.com/caselaws?id=36455 Section 251 enhancement power is confined to the subject-matter of the assessment and to income sources considered by the Income-tax Officer, expressly or by necessary implication, for taxability. It does not authorise the appellate authority to travel outside the original record and assess fresh sources of income not processed in the assessment proceedings. The Explanation to section 251 allows consideration of matters arising out of the proceedings in which the order appealed against was passed, but it does not extend that jurisdiction to new matters never raised or examined before the assessing authority. Accordingly, appellate enhancement cannot be used to add undisclosed income from a fresh source. en-us Thu, 28 Feb 1980 00:00:00 +0530 Mon, 22 Mar 2010 14:51:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36455 Section 251 enhancement power is confined to the subject-matter of the assessment and to income sources considered by the Income-tax Officer, expressly or by necessary implication, for taxability. It does not authorise the appellate authority to travel outside the original record and assess fresh sources of income not processed in the assessment proceedings. The Explanation to section 251 allows consideration of matters arising out of the proceedings in which the order appealed against was passed, but it does not extend that jurisdiction to new matters never raised or examined before the assessing authority. Accordingly, appellate enhancement cannot be used to add undisclosed income from a fresh source. Case-Laws Income Tax Thu, 28 Feb 1980 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36455