https://www.taxtmi.com/caselaws?id=790316 Section 251(1) limits appellate enhancement to matters already examined in assessment; a fresh source or new issue not considered by the Assessing Officer cannot be introduced, so the enhancement for reducing work-in-progress was without jurisdiction. A receipt under a joint development arrangement was not a loan or advance, and since the recipient was neither a registered nor beneficial shareholder, it could not be taxed as deemed dividend under section 2(22)(e) in the recipient's hands. The consideration under the joint development agreement was contractually fixed as constructed area, so substituting the stamp duty value of the entire land parcel was not sustainable where the asset was treated as stock-in-trade. en-us Fri, 17 Apr 2026 00:00:00 +0530 Thu, 23 Apr 2026 09:45:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790316 Section 251(1) limits appellate enhancement to matters already examined in assessment; a fresh source or new issue not considered by the Assessing Officer cannot be introduced, so the enhancement for reducing work-in-progress was without jurisdiction. A receipt under a joint development arrangement was not a loan or advance, and since the recipient was neither a registered nor beneficial shareholder, it could not be taxed as deemed dividend under section 2(22)(e) in the recipient's hands. The consideration under the joint development agreement was contractually fixed as constructed area, so substituting the stamp duty value of the entire land parcel was not sustainable where the asset was treated as stock-in-trade. Case-Laws Income Tax Fri, 17 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790316