THE NEW JEHANGIR VAKIL MILLS LTD. vs THE COMMISSIONER OF INCOME-TAX, BOMBAYNORTH, KUTCH AND SAU

The Supreme Court held that under Section 66(4) of the Indian Income-tax Act, 1922, the High Court does not have the authority to raise new questions of law or direct the Income-tax Appellate Tribunal to investigate new facts not previously referred. The Court found that the High Court had misconceived its powers by attempting to inquire into matters not raised by the parties or decided by the Tribunal. Consequently, the High Court's order was set aside, reaffirming that the High Court's role is limited to the facts already part of the record.