CIT(A) cannot enhance income based on sources not considered during assessment

Hari Mohan Sharma Vs ACIT (ITAT Delhi) Conclusion: Enhancement u/s 251 (1) (a) is prohibited on the issues which have not at all been considered by AO during assessment proceedings, therefore, CIT (A) had exceeded his jurisdiction in enhancing the income of assessee by considering the new sources of income not at all considered by AO. Held: In the present case, assessee declared capital gain on sale of certain property. AO was concerned with respect to claim of the assessee u/s 54F which was rejected after inquiry and relying up on the decision of the Honourable Supreme court. CIT (A) had made...