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Case lawSupreme Court › Hukumchand Mills Ltd v CIT
Supreme CourtCuts both wayss.33(4) of the Indian Income-tax Act, 1922s.10(5)(b) of the Indian Income-tax Act, 1922s.254(1)s.43(6)

Hukumchand Mills Ltd v CIT

The Department raised a completely new ground before the Tribunal to support the assessment, and the Tribunal allowed it and remanded. Was the Tribunal entitled to do that?

The Department raised a completely new ground before the Tribunal to support the assessment, and the Tribunal allowed it and remanded. Was the Tribunal entitled to do that?

Yes. The Supreme Court held that the Tribunal's power under section 33(4) of the 1922 Act to pass such orders as it thinks fit is expressed in the widest possible terms. The word 'thereon' confines it to the subject matter of the appeal, but within that subject matter the Tribunal may allow a ground to be raised for the first time and may direct a further enquiry. The subject matter here was the written down value of the assessee's buildings and machinery, and it was open to the Department to support the finding on that on any ground decided against it. The Appellate Tribunal Rules are procedural and do not cut down the section.

Decided by the Supreme Court (Supreme Court of India - J.C. Shah, V. Ramaswami and Vishishtha Bhargava, JJ (judgment delivered by Ramaswami, J)) on 1966-09-22, reported as 1967 AIR 455; 1967 SCR (1) 463. It bears on section 33(4) of the Indian Income-tax Act, 1922, section 10(5)(b) of the Indian Income-tax Act, 1922, section 254(1), section 43(6) of the Income Tax Act 1961, in Appeals matters.

Still good law. The standard authority on the width and limits of the Tribunal's appellate power; the harvested page records it as followed in a 1969 Supreme Court decision and relied on in 1980, and as cited in more than two hundred decisions. No later decision doubting it was read as part of this exercise. Section 254(1) of the 1961 Act is in similar terms but was not before the Court, and the Tribunal now works under its own rules.

Why it matters

This is the standard authority on the width of the Tribunal's appellate power and on its limit. The two halves matter equally. The width: the words 'pass such orders as it thinks fit' carry all the powers of the first appellate authority except, possibly, enhancement, including the power to direct a further enquiry and dispose of the case on it; and the Rules, being procedural, neither exhaust nor control that power. The limit: 'thereon' ties the Tribunal to the subject matter of the appeal, which is the line every argument about new grounds is fought on. It is also the case for the respondent who has not appealed - he may support the order below on any ground decided against him.

Binding on every court and authority in India.

Not yet CA-verified. This entry was found through the sources listed under the Sources tab, and the summary reflects what those sources say. Nobody has yet read the full judgment and signed it off. Check the source before relying on it.

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