JUTE CORPORATION OF INDIA LTD. vs COMMISSIONER OF INCOME TAX AND ANR.

The Supreme Court held that under Section 251 of the Income Tax Act, 1961, the Appellate Assistant Commissioner has the jurisdiction to entertain additional grounds raised by the assessee that were not previously raised before the Income Tax Officer. The Court clarified that the appellate authority's powers are co-terminus with those of the original authority, allowing for modifications to the assessment order based on additional grounds. The Court emphasized that the Appellate Assistant Commissioner must exercise discretion reasonably, ensuring that the additional ground is bona fide and could not have been raised earlier for valid reasons.