The assessee filed an appeal against the order of the CIT(A) for AY 2018-19. The assessee sought to admit additional evidence to support contentions regarding rental income and remuneration paid to directors.

What were the issues?

Whether additional evidence, not filed before lower authorities, should be admitted and considered by the AO for a fair adjudication of the issues.

Jayant Packaging Pvt. Ltd. vs ITO | ITAT Chennai 2026

Q: What did the Tribunal hold?

The Tribunal found it appropriate to remand the matter to the AO for fresh consideration of the additional evidence. The AO was directed to pass an order after considering this evidence.

Before: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

Hearing: 17.06.2026Pronounced: 21.07.2026

आयकर अपीलीय अिधकरण, ’ए’ �ायपीठ, चे�ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI �ी इंटूरी रामाराव, लेखा सद� एवं �ी एस.एस. िव�ने� रिव, �ाियक सद� के सम� । Before Shri Inturi Rama Rao, Accountant Member & Shri S.S. Viswanethra Ravi, Judicial Member आयकर अपील सं./I.T.A. No.1465/Chny/2025 िनधा�रण वष�/Assessment Year: 2018-19 Jayant Packaging Pvt. Ltd., Vs. The ITO. Super A 12/13, Industrial Corp. Ward-2(3), Estate, Guindy,Chennai, Chennai. 600032, Tamilnadu. [PAN: AAACJ1799A] (अपीलाथ�/Appellant) (��थ�/Respondent) अपीलाथ� की ओर से / Appellant by : Mr. A. Satyaseelan, Advocate ��थ� की ओर से/Respondent by : Mr. S. Manoj Prakash, JCIT सुनवाई की तारीख/ Date of hearing : 17.06.2026 घोषणा की तारीख /Date of Pronouncement : 21.07.2026 आदेश /O R D E R PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER: This appeal filed by the assessee is directed against the order dated 21.03.2025 passed by the ld. Commissioner of Income Tax (Appeals), NFAC, Delhi for the assessment year 2018-19.

At the outset, it is noted that the ld. AR, Mr. A. Satyaseelan, Advocate, drew our attention to the petition for admission of additional evidence under Rule 29 of the ITAT Rules, 1963, and submits that the evidence shown under items 3, 4, 5, 6, 9, and 17 of the paper book is

2 I.T.A. No.1465/Chny/25

filed for the first time in support of the contentions of the assessee with reference to two issues, i.e., rental income and remuneration paid to the Directors. He submits that the non-filing of those documentary evidences was neither willful nor wanton since the said documents only show the additional proof of the existence of the factory at the place where the information technology building was constructed. Further, with reference to the remuneration paid to the Directors, the documents shown under items 12, 14, 15, and 16 are also in support of the contention with reference to the disallowance of remuneration paid to the Directors. He prayed to remand the matter to the file of the AO for his fresh consideration, as the additional evidence as reflected in the paper book is necessary for fair adjudication of the issues.

Ld. DR, Mr. S. Manoj Prakash, JCIT, reported no objection.

Considering the facts and circumstances of the case and in the interest of justice, the only contention of the ld. AR is that the said documents are in support of the two issues as disputed in the present appeal, which were not filed before the AO and the ld. CIT(A). We find no dispute from the Revenue side. Thus, we deem it proper to remand the matter to the file of the AO for his fresh consideration of the additional evidence filed before us in the paper book, and the AO shall pass the

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order after considering the same. The assessee is at liberty to file the same before the AO. Thus, the order of the ld. CIT(A) is set aside and the grounds raised by the assessee are allowed for statistical purposes.

In the result, the appeal of the assessee is allowed for statistical purposes.

Order pronounced on 21st July, 2026 at Chennai.

Sd/- Sd/- (INTURI RAMA RAO) (S.S. VISWANETHRA RAVI) ACCOUNTANT MEMBER JUDICIAL MEMBER Chennai, Dated, 21.07.2026 MM/- आदेश की �ितिलिप अ�ेिषत/Copy to: 1. अपीलाथ�/Appellant, 2.��थ�/ Respondent, 3. आयकर आयु�/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय �ितिनिध/DR & 5. गाड� फाईल/GF. Digitally signed MANIS by MANISH MISHRA H Date: 2026.07.23 MISHRA 09:37:30 +05'30'

JAYANT PACKAGING PVT. LTD. ,CHENNAI vs. ITO, CORP. WARD-2(3), CHENNAI

What did the Tribunal hold?

What were the facts?

What were the issues?

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