HUKUMCHAND MILLS LTD. vs COMMISSIONER OF INCOME-TAX, CENTRAL BOMBAY & ORS.

The Supreme Court held that under Section 33(4) of the Income-tax Act, 1922, the Income-tax Appellate Tribunal has the jurisdiction to entertain new arguments raised by the Department and to remand cases for further consideration. The Court clarified that the Appellate Tribunal Rules, 1946, are procedural and do not limit the Tribunal's powers under Section 33(4). Consequently, the Tribunal's decision to remand the case for determining the proper written down value for depreciation allowance was upheld.