CIT(A) cannot tax a new source of income which was not part of original assessment

ACIT Vs Versatile Polytech P. Ltd (ITAT Delhi)

Conclusion: Although the powers of the CIT(A) were co-terminus with that of the powers of AO, yet, it had jurisdiction only on those items which had been considered by AO irrespective of the fact whether the issue was subject matter of appeal or not. Thus, where AO  in the assessment order had neither discussed the issue nor made any addition Please become a Premium member. If you are already a Premium member, login here to access the full content.