JUDGMENT

In this appeal, by special leave, the question that falls for consideration relates to the scope of the powers of the Appellate Assistant Commissioner while dealing with appeals against orders of the Assessing Officers under Section 251 of the Income Tax Act, 1961 (hereinafter referred to as the Act ). The matter relates to the assessment year 1956-57. M/s. Nirbheram Daluram (hereinafter referred to as the assessee ) is a partnership firm carrying on business in grains, rice, gunny bags and oil seeds, etc. Under order dated March 11, 1957 assessment was originally made on a total income of Rs. 28,724/-. On re-assessment in proceedings initiated under Section 147 of the Act the Income Tax Officer included in the total income a sum of Rs. 2,45,000/- referable to ostensible transactions in hundi loans shown by the assessee. The assessee filed an appeal against the said assessment order passed by the Income Tax Officer. The Appellate Assistant Commissioner not only sustained the said addition of Rs. 2,45,000/- but he also took notice of 10 other items of ostensible hundi loans amounting to Rs. 2,30,000/- and directed that the total income be enhanced by the sum of Rs. 2,30,0