ADDITIONAL COMMISSIONER OF INCOME TAX,GUJARAT, I, AHMEDABAD vs M/S. GURJARGRAVURES PRIVATE LIMITED

The Supreme Court held that under Section 251(1)(a) of the Income-tax Act, 1961, the Appellate Assistant Commissioner's powers do not extend to entertain claims not made before the Income-tax Officer. The Court clarified that 'consideration' requires the Income-tax Officer to apply his mind to the taxability of income, and mere notice of income without examination does not constitute consideration. The Court reversed the Gujarat High Court's decision, ruling that the assessee's claim for exemption under Section 84 was not valid as it was not raised during the initial assessment.