COMMISSIONER OF INCOME-TAX, KERALA vs M/S. MANICK SONS

The Supreme Court held that under Section 33(4) of the Income-tax Act, 1922, the Income-tax Appellate Tribunal cannot amalgamate the income of two assessment years and divide it equally between them. The Tribunal must exercise its powers judicially and cannot assume powers inconsistent with the Act's provisions. The Court ruled that the Tribunal's allowance for 'intangible additions' without reasons was invalid, and it cannot direct reassessment for years not covered by the appeal, thus allowing the appeal and setting aside the Tribunal's order.