What did the Tribunal hold?

The tribunal held that the CIT(A) erred by rejecting additional evidence without following established jurisprudence and prioritizing technicalities over substantive justice. The matter was restored to the CIT(A) for fresh adjudication.

The assessee preferred appeals against the NFAC's order for AYs 2017-18 and 2018-19. The core issue was the rejection of additional evidence filed under Rule 46A by the CIT(A).

What were the issues?

Whether the CIT(A) was justified in rejecting additional evidence filed under Rule 46A without proper consideration and adherence to legal precedents.

Quasar Media Private Limited… vs ACIT | ITAT Delhi 2026

Income Tax Appellate Tribunal, DELHI ‘G’ BENCH,

Before: SHRI SATBEER SINGH GODARA, & SHRI NAVEEN CHANDRA

For Appellant: Shri Nitin Kumar Sharma, CA

For Respondent: Shri Ravi Kant Choudhary, Sr. DR

Hearing: 18.05.2026Pronounced: 18.05.2026

Heard together (2 matters)

ITA No. 6194/Del/2025

ITA No. 6195/Del/2025

Read from the judgment's own cause title. This page is filed under one of them.

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘G’ BENCH, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER, AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 6194/Del/2025 [A.Y. 2017-18] ITA No. 6195/Del/2025 [A.Y. 2018-19]

Quasar Media Pvt. Ltd. Vs. The ACIT 8th Floor, 405B, Tower-B Circle – 19(1) DLF Cyber Park, Sector-20, New Delhi Udyog Vihar Phase – 3, Gurgaon - 122 016 PAN – AAACQ 1247 Q (Applicant) (Respondent) Assessee By : Shri Nitin Kumar Sharma, CA Department By : Shri Ravi Kant Choudhary, Sr. DR

Date of Hearing : 18.05.2026 Date of Pronouncement : 18.05.2026 ORDER PER NAVEEN CHANDRA, ACCOUNTANT MEMBER:-

Both the appeals by the assessee is preferred against the order of the NFAC, Delhi dated 22.07.2025 pertaining to A.Ys. 2017-18 & 2018-19.

ITA Nos. 6194 & 6165/DEL/2025 [A.Ys. 2017-18 & 2018-19] Quasar Media Pvt. Ltd. vs. ACIT 2. Since the above captioned appeals were heard together and the facts in issues are identical, all these appeals are being disposed of by this common order for the sake of convenience and brevity.

The solitary issue in these appeals are as under: “The Learned Commissioner of Income Tax (Appeals) has erred both on facts and in law in rejecting all additional evidences, filed in terms of Rule 46A of Income Tax Rules 1961 by not following jurisprudence laid down by the Hon'ble High Court of Delhi in the case of Commissioner of Income-tax v. Hewlett Packard India (P.) Ltd [2008] 173 Taxman 162 (Delhi) and also by Hon'ble ITAT (Mumbai) in the case of Shahrukh Khan v. Deputy Commissioner of Income-tax, Spl. Rg. 21, Mumbai [2007] 13 SOT 61 Mumbai.” 4. At the very outset, the ld. counsel for the assessee submitted that the ld. CIT(A) has decided the issues without providing adequate opportunity of being heard to the assessee to present its case. It is the say of the ld. counsel for the assessee that several additional evidences have been submitted before the ld. CIT(A) which were not admitted. He, therefore, prayed that since neither the Assessing Officer nor the ld. CIT(A) examined the evidences produced before the ld. CIT(A), the matter may be remitted back to the Assessing Officer for adjudication of the additional/fresh evidence with regard to the subject matter in the assessee instant appeal. 5. Per contra, the ld. DR did not raise any serious objection and relied upon the orders of the authorities below. Page 2 of 5

ITA Nos. 6194 & 6165/DEL/2025 [A.Ys. 2017-18 & 2018-19] Quasar Media Pvt. Ltd. vs. ACIT 6. We have heard the rival submissions and have perused the relevant material on record. We find that the ld. CIT(A) has rejected the additional evidences filed in terms of Rule 46A of the Act on the ground of objection raised by the AO that assessee was given several opportunities which were not availed of. We find that the CIT(A) did not follow the jurisprudence laid down by the Hon'ble High Court of Delhi in the case of Commissioner of Income-tax v. Hewlett Packard India (P.) Ltd [2008] 173 Taxman 162 (Delhi) and also by Hon'ble ITAT (Mumbai) in the case of Shahrukh Khan v. Deputy Commissioner of Income-tax, Spl. Rg. 21, Mumbai [2007] 13 SOT 61 Mumbai. The ld. CIT(A) has accorded primacy to the technicality of Rule 46A of the I.T. Rules and has ignored the principles of substantive justice. In view of the above facts and circumstances and in the interest of justice and fair play, we are of the considered view that the matter be restored back to the file of the learned CIT(A) to examine the additional evidences and decide the issues afresh after allowing adequate opportunity of being heard to the assessee. The assessee is also directed to provide necessary information/documents as required by the authorities and co-operate in adjudication of the issues at hand. Ground 2 allowed for statistical purposes. Page 3 of 5

ITA Nos. 6194 & 6165/DEL/2025 [A.Ys. 2017-18 & 2018-19] Quasar Media Pvt. Ltd. vs. ACIT 7. In the result, both the appeals of the assessee in ITA Nos. 6164 & 6165/Del/2025 are allowed for statistical purposes. The order is pronounced in the open court on 18.05.2026./- Sd/- Sd/- [SATBEER SINGH GODARA] [NAVEEN CHANDRA] JUDICIAL MEMBER ACCOUNTANT MEMBER Dated: 26th May, 2026. Priti Yadav, Sr. PS* Copy forwarded to: 1. Assessee 2. Respondent 3. CIT 4. CIT(A) Asst. Registrar, 5. DR ITAT, New Delhi

Page 4 of 5

QUASAR MEDIA PRIVATE LIMITED,GURGAON vs. ACIT, CIRCLE-19(1), DELHI

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