https://www.taxtmi.com/caselaws?id=468149 Appellate enhancement cannot be used to recast the very nature of an assessed receipt on a new footing. Where the Assessing Officer had treated cash deposits as business income, the first appellate authority could not, on the same material, recharacterise them as unexplained money under section 69A and tax them under section 115BBE merely by invoking enhancement powers. The power of enhancement does not extend to making a fresh and different assessment of the same receipt without a permissible basis for changing its head of income. The attempted reclassification was therefore held unsustainable and was set aside in favour of the assessee. en-us Mon, 03 Feb 2025 00:00:00 +0530 Fri, 17 Apr 2026 22:39:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468149 Appellate enhancement cannot be used to recast the very nature of an assessed receipt on a new footing. Where the Assessing Officer had treated cash deposits as business income, the first appellate authority could not, on the same material, recharacterise them as unexplained money under section 69A and tax them under section 115BBE merely by invoking enhancement powers. The power of enhancement does not extend to making a fresh and different assessment of the same receipt without a permissible basis for changing its head of income. The attempted reclassification was therefore held unsustainable and was set aside in favour of the assessee. Case-Laws Income Tax Mon, 03 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468149