https://www.taxtmi.com/caselaws?id=39767 Appellate enhancement in income-tax proceedings is confined to the subject-matter of the assessment and to income sources expressly or by clear implication considered by the Income-tax Officer. The power under section 31(3) of the 1922 Act and section 251(1) of the 1961 Act is in pari materia, but it does not authorise the appellate authority to travel beyond the record and introduce a fresh source of income not processed by the assessing officer or disclosed in the return or assessment order. Additions made on undisclosed sources were therefore unsustainable, and the assessee succeeded. en-us Fri, 31 May 1974 00:00:00 +0530 Tue, 20 Apr 2010 11:58:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39767 Appellate enhancement in income-tax proceedings is confined to the subject-matter of the assessment and to income sources expressly or by clear implication considered by the Income-tax Officer. The power under section 31(3) of the 1922 Act and section 251(1) of the 1961 Act is in pari materia, but it does not authorise the appellate authority to travel beyond the record and introduce a fresh source of income not processed by the assessing officer or disclosed in the return or assessment order. Additions made on undisclosed sources were therefore unsustainable, and the assessee succeeded. Case-Laws Income Tax Fri, 31 May 1974 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39767