CIT(A) can't introduce new income sources during appeals; deemed dividends under Sec 2(22)(e) not allowed.

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....Powers of CIT(A) u/s 251 - Enhancement of assessment - New source of income introduced by CIT(A) while deciding the appeal and enhancement of income - Deemed dividend u/s.2(22)(e) - The issue of deemed dividend u/s.2(22)(e) of the Act, were never subject matter of assessment order - enhancement made by CIT(A) on altogether new issues is without authority of law - AT....