https://www.taxtmi.com/caselaws?id=794806 Appellate enhancement under section 251(2) of the Income-tax Act is confined to the subject matter of assessment and issues considered by the Assessing Officer, expressly or by clear implication. A Commissioner (Appeals) cannot introduce a new source of income, such as alleged commission, where that source was not examined in the assessment proceedings or reflected in the assessment order. If tax on a new source is to be pursued, the Act provides separate statutory remedies. The commentary states that enhancement on such a basis is beyond appellate jurisdiction and cannot survive. en-us Wed, 08 Jul 2026 00:00:00 +0530 Sat, 11 Jul 2026 08:46:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794806 Appellate enhancement under section 251(2) of the Income-tax Act is confined to the subject matter of assessment and issues considered by the Assessing Officer, expressly or by clear implication. A Commissioner (Appeals) cannot introduce a new source of income, such as alleged commission, where that source was not examined in the assessment proceedings or reflected in the assessment order. If tax on a new source is to be pursued, the Act provides separate statutory remedies. The commentary states that enhancement on such a basis is beyond appellate jurisdiction and cannot survive. Case-Laws Income Tax Wed, 08 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794806