BASANT KUMAR MISHARA, KORBA,KORBA vs. DCIT, CIRCLE-1(1), BILASPUR, BILAPSUR

ITA 71/RPR/2026Status: HeardITAT Raipur19 March 2026AY 2018-19Bench: SHRI PARTHA SARATHI CHAUDHURY (Judicial Member)1 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the CIT(A)/NFAC, as a quasi-judicial authority, erred by not considering the additional evidence without cogent reasons. It set aside the orders of the CIT(A)/NFAC and remanded both the quantum and penalty appeals back for fresh consideration, with directions to admit and consider the additional evidence and issue a speaking order.

What were the facts?

The assessee appealed against the orders of the Ld. CIT(Appeals)/NFAC for Assessment Year 2018-19. The Ld. CIT(A) had rejected the admission of additional evidence, specifically a claim for expenses of Rs. 21,49,846/-, under Rule 46A, on the grounds that the assessee had ample opportunity during original assessment proceedings.

What were the issues?

Whether the CIT(A)/NFAC was justified in rejecting additional evidence under Rule 46A, and if a quasi-judicial authority is obligated to consider all relevant evidence for a just decision.

Which sections of the Income-tax Act were involved?

Section 46A,Section 250(4),Section 250(6)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH “SMC”, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY

For Appellant: Shri Yash Dhariwal, CA
For Respondent: Dr. Priyanka Patel, Sr. DR
Hearing: 19.03.2026Pronounced: 19.03.2026

PER PARTHA SARATHI CHAUDHURY, JM The captioned appeals preferred by the assessee emanates from the respective orders of the Ld.CIT(Appeals)/NFAC, Delhi dated 13.11.2025 & 14.11.2025 for the assessment year 2018-19 as per the grounds of appeal on record.

2.

At the very outset, it is noted that the Ld. CIT(Appeals)/NFAC vide Para 6.5.1 had not accepted the additional evidences observing as follows:

“6.5.1 A

The order continues below.

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