MAHENDRA MILLS LTD. vs SHERI P. B. DESAI, APPELLATE ASSISTANT COMMISSIONER O

The Supreme Court held that under Section 35 of the Income-Tax Act, 1961, the record of appeal includes the assessment records of previous years when determining the opening stock for a subsequent assessment year. The Court clarified that the Appellate Assistant Commissioner could rectify his decision by considering the Tribunal's findings from the earlier assessment year, as the closing stock of one year directly impacts the opening stock of the next. The appeal was dismissed, affirming the High Court's ruling that the Appellate Assistant Commissioner acted within his jurisdiction.