Raj Kumar Srimal v. CIT

102 ITR 525High Court1976#4269 most cited

What is Raj Kumar Srimal v. CIT authority for?

The Commissioner of Income Tax (Appeals) [CIT(A)] can admit new grounds or evidence, either on their own or at the parties' request, but if admitted at the assessee's invitation, there must be a valid explanation for not producing the evidence earlier.

27

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2017 to 2025.

Also referred to as

Raj Kumar Srimal v. CIT · 102 ITR 525 · admission of new ground · admission of new evidence · appellate stage · CIT(A) · explanation for failure to adduce evidence · violation of natural justice

Sections most often in play

Section 119Section 132(1)Section 143(3)Section 144ASection 153ASection 153CSection 153DSection 158BG

Issues it is cited on

section 153(a)violation of natural justicesection 132(4a)section 40a(3)section 132(1)section 153a(1)section 145(3)section 40arule 46asearch assessmentsection 153dsection 145

Judgments citing Raj Kumar Srimal v. CIT

Ramji Vaish, Allahabad vs. DCIT(CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 38/ALLD/2023[2007-08]Status: DisposedITAT Allahabad31 Oct 2025AY 2007-08

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…rcumstances of the case and in law, the CIT(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objecti…

Ramji Vaish, Allahabad vs. DCIT, (CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 37/ALLD/2023[2006-07]Status: DisposedITAT Allahabad31 Oct 2025AY 2006-07

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…rcumstances of the case and in law, the CIT(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objecti…

Ramji Vaish, Allahabad vs. DCIT, (CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 36/ALLD/2023[2005-06]Status: DisposedITAT Allahabad31 Oct 2025AY 2005-06

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…rcumstances of the case and in law, the CIT(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objecti…

Ramji Vaish, Allahabad vs. DCIT(CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 127/ALLD/2023[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…rcumstances of the case and in law, the CIT(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objecti…

Ramji Vaish, Allahabad vs. DCIT(CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 126/ALLD/2023[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…rcumstances of the case and in law, the CIT(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objecti…

Ramji Vaish, Allahabad vs. DCIT(CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 125/ALLD/2023[2009-10]Status: DisposedITAT Allahabad31 Oct 2025AY 2009-10

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…rcumstances of the case and in law, the CIT(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objecti…

Ramji Vaish, Allahabad vs. DCIT(C.C.), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 101/ALLD/2023[2008-09]Status: DisposedITAT Allahabad31 Oct 2025AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…rcumstances of the case and in law, the CIT(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objecti…

Asstt. Commissioner of Income Tax, Central Circle, Allahabad vs. Vijay Stone Product, Sonebhadra

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 65/ALLD/2019[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…rcumstances of the case and in law, the CIT(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objecti…

Asstt. Commissioner of Income Tax Central Circle, Allahabad vs. Vijay Stone Products, Sonebhadra

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 64/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…rcumstances of the case and in law, the CIT(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objecti…

Vijay Stone Product, Sonebhadra vs. Asstt. Commissioner of Income Tax, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 33/ALLD/2019[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…rcumstances of the case and in law, the CIT(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objecti…

Vijay Stone Product, Sonebhadra vs. Asstt. Commissioner of Income Tax, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 32/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…rcumstances of the case and in law, the CIT(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objecti…

Vijay Stone Product, Sonebhadra vs. Asstt. Commissioner of Income Tax, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 31/ALLD/2019[2009-10]Status: DisposedITAT Allahabad31 Oct 2025AY 2009-10

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…rcumstances of the case and in law, the CIT(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objecti…

Vijay Stone Product, Sonebhadra vs. Asstt. Commissioner of Income Tax, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 30/ALLD/2019[2007-08]Status: DisposedITAT Allahabad31 Oct 2025AY 2007-08

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…rcumstances of the case and in law, the CIT(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objecti…

M/S Jai Maa Sharda Service Station, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 25/ALLD/2019[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…rcumstances of the case and in law, the CIT(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objecti…

M/S Jai Maa Sharda Service Station, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 24/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…rcumstances of the case and in law, the CIT(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objecti…

M/S Subhash Stone Product Private Limited, Sonebhadra vs. Asstt. Commissioner of Income Tax Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 108/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…rcumstances of the case and in law, the CIT(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objecti…

Subhash Stone Product (P) Ltd., Sonebhadra vs. Asstt. Commissioner of Income Tax Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 107/ALLD/2019[2008-09]Status: DisposedITAT Allahabad31 Oct 2025AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…rcumstances of the case and in law, the CIT(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objecti…

Shree Cement Limited, Bangur Nagar vs. ACIT, Central Circle, Ajmer

In the result, the appeal of the assessee - appellant in ITA No

ITA 1517/JPR/2024[2019-2020]Status: DisposedITAT Jaipur24 Jun 2025AY 2019-2020

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Dilip B. Desai, FCAFor Respondent: Shri Arvind Kumar, CIT-DR
Section 115JSection 143(1)Section 254Section 36(1)(va)Section 80Section 801A

…same could not have been raised earlier for good reasons. The satisfaction of the AAC depends upon the facts and circumstances of each case and no rigid principles or any hard and fast rule can be laid down for this purpose. In Rai Kumar Srimal v. CIT [1976] 102 ITR 525, a Division Bench of the Calcutta High Court presided over by Sabyasachi Mukharji, J, as he then was, held that the AAC was entitled to admit new ground or evidence either suo motu or at the invitation of the parties. If he is acting on being invited by the assesee, then there must be some ground for admitting new evidence in the sense that there…

Deputy Commissioner of Income Tax, Circle-1(1), New Delhi, Delhi vs. Acore Consulting Pvt Ltd, Dlehi

In the result, the appeal of the Revenue in ITA No

ITA 1308/DEL/2024[2014-15]Status: DisposedITAT Delhi13 Aug 2024AY 2014-15

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri C.S. Anand, AdvFor Respondent: Shri Kanv Bali, Sr. DR

…tion is to be recorded by the appellate authority in writing and with which the appellate authority is further required to confront the assessing officer and allow him reasonable opportunity to have his say in the matter. In the case of Rajkumar Srimal v. CIT 102 ITR 525 (Cal) the Hon'ble Calcutta High Court have clearly held that where the CIT is not acting suo motu in admitting additional evidence, there must be some ground for admitting new evidence. The Hon'ble Calcutta High Court have further observed that in such a case the Tribunal can interfere with the discretion exercised by the first appellate authorit…

Jaipur Jewellery Show, Jaipur vs. ACIT-DCIT Circle (Exemp.), Jaipur

In the result, the appeal of the assesee is allowed for statistical purposes

ITA 164/JPR/2024[2012-13]Status: DisposedITAT Jaipur10 Jun 2024AY 2012-13

Bench: Hon’ble SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Rajeev Sogani, CAFor Respondent: Shri Rajesh Kumar Meena, Addl. CIT-DR
Section 11Section 12ASection 143(3)Section 250Section 264

…v. Taylor Instrument Co. (India) Ltd.v.Commissioner of Income-tax, [1992] 64 Taxman 129 (Delhi) “23. The Supreme Court in Jute Corporation of India's case (supra), specifically approved the decision of the Calcutta High Court in Rai Kumar Srimal v. CIT [1976] 102 ITR 525, wherein it had been held that the AAC was entitled to admit new ground or evidence either suo motu or at the invitation of the parties.” v. Sesa Goa Ltd.v.Additional Commissioner of Income-tax, Panaji, Goa, [2020] 117 taxmann.com 548 (Bombay) 10 JAIPUR JEWELLERY SHOW VS ACIT ,CIRCLE (EXEMPTION), JAIPUR “15. The circumstance that we have observ…

Raj Kumar Srimal v. CIT (102 ITR 525) — Cited in 27 Judgments | BharatTax