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Bhartiben Bharatbhai Patel, Ahmedabad vs Department Of Income Tax on 29 December, 2005 cites

Saheli Synthetics (P.) Ltd. vs Assistant Commissioner Of Income-Tax on 19 October, 1995

Hon'ble Gujarat High Court in the case of Saheli Synthetics Pvt Ltd v. CIT, 302 ITR126 also categorically took a similar view in the background of the aforesaid decision of the Hon'ble Supreme Court in CIT v. Rai Bahadur Hardutroy Motilal Chamaria (Supra) wherein the Hon'ble Supreme Court categorically observed and noted that it is not open to the Appellate Authority to travel outside the record, that is, the return made by the assessee or the assessment order of the Income Tax Officer with a view to point out a new source of income. In the light of view taken in these decisions, we are of the opinion that a new round can be permitted in appeal so long as the relevant facts are on record and the ground sought to be raised could not have been raised earlier for good reasons.
Income Tax Appellate Tribunal - Ahmedabad Cites 4 - Cited by 9 - Full Document

National Thermal Power Corporation ... vs Addl. Commissioner Of Income Tax on 26 May, 2004

As noted in National Thermal Power Corporation Ltd v. CIT, 229 ITR 383(SC), the Tribunal has the discretion to allow or not to allow a new ground to be raised. A new ground may be allowed to be raised only when it arises from the facts which are on record. Since issues raised in the aforesaid additional grounds in the appeal before us do not emerge from the impugned order nor have been raised before the ld. CIT(A), accordingly, in the light of aforesaid decisions of the Hon'ble Apex Court and jurisdictional High Court, we have no alternative but to reject the prayer of admission of the aforesaid additional grounds .
Income Tax Appellate Tribunal - Delhi Cites 5 - Cited by 251 - Full Document
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