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“admission of additional evidence”

AppealsRule 46ARule 46A1,576 judgments

The decision most relied on for admission of additional evidence is CBI v. V.C. Shukla (3 SCC 410), cited in 442 judgments on BharatTax.

Leading authorities on admission of additional evidence

CBI v. V.C. Shukla
3 SCC 410 · 1998 · Supreme Court
442
citing judgments

Loose sheets of paper, excel sheets, or diaries, often referred to as 'dumb documents,' are wholly irrelevant as evidence and not admissible under Section 34 of the Evidence Act if they lack evidentiary value. Additions to income cannot be made solely based on such documents without corroborating, reliable, and admissible evidence supported by other circumstances.

Common Cause v. Union of India
77 Taxmann.com 245 · 2017 · Supreme Court
267
citing judgments

Additions under the Income Tax Act cannot be made solely based on entries in loose sheets, dumb documents, or mere sworn statements without independent, reliable, and cogent corroborating evidence. Uncorroborated loose papers are not admissible evidence on their own, even if the original context was criminal investigation.

Shri Kailashben Manharlal Chokshi v. CIT
174 Taxmann 466 · 2008 · High Court
225
citing judgments

Liability cannot be fastened solely on the basis of a self-incriminating sworn statement made during a search, as such statements are not conclusive and require corroborative evidence.

Smt. Prabhavati S. Shah v. CIT
231 ITR 1 · 1998 · High Court
186
citing judgments

The first appellate authority must admit additional evidence if it is necessary for determining the true state of affairs and preventing undue hardship or a failure of justice, even without a specific request and particularly when the case falls under Rule 46A(1)(c).

CIT v. Manish Build Well (P) Ltd.
16 Taxmann.com 27 · 2011 · High Court
120
citing judgments

The CIT(A) must strictly comply with Rule 46A of the Income-tax Rules for admitting additional evidence, ensuring all prescribed conditions exist, reasons are recorded, and reasonable opportunity is provided to the Assessing Officer.

CIT v. Sunil Aggarwal
64 Taxmann.com 107 · 2015 · High Court
113
citing judgments

An addition of an unexplained cash credit based solely on an assessee's retracted admission made during a search and seizure operation is not justified, especially if the assessee later provides verifiable explanations.

CIT v. P.V. Kalyanasundaram
282 ITR 259 · 2006 · High Court
108
citing judgments

Seized loose sheets or unsigned documents discovered during a search operation possess admissible evidentiary value and can form the basis for income additions if corroborated by external evidence, such as matching payments, business records, or corroborative statements.

CIT v. Text Hundred India Pvt. Ltd.
351 ITR 57 · 2013 · High Court
88
citing judgments

The Tribunal has the discretion to admit additional evidence, even if filed by a party, when it deems it necessary for proper adjudication and to achieve substantial justice. This power can be exercised in the interest of justice.

Judgments citing admission of additional evidence

Anand Ashok Chandavarkar, Mumbai vs. Income Tax Officer Ward 31 1 1 Mumbai, Mumbai

In the result, the grounds of appeal and the appeal filed by the assessee is allowed for statistical purposes

ITA 3808/MUM/2024[2012-13]Status: DisposedITAT Mumbai12 Nov 2025AY 2012-13

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankaranand Ashok Chandavarkar V/S. Income Tax Officer, Ward – C/O S.S. Tumkar, 202, Shreeji बनाम 31(1)(1), Room No. 203, 2Nd Darshan Chsl, Hanuman Floor, Kautilya Bhavan, C-41 Road, Ville Parle East, To C-43, G-Block, Bandra Mumbai – 400 057, Kurla Complex, Bandra Maharashtra (East), Mumbai – 400 051, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Ablpc0382R Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Jitendra Singh & Ms. Shivali MhatreFor Respondent: Shri Bhagirath Ramawat (Sr. DR)
Section 144Section 147Section 148Section 69A

valid notice under section 148 of the Act is void ab initio and the same may be quashed. 3. Rejecting the application for admission of additional evidences is unjustified. The Ld.CIT(A) erred in summarily rejecting the application made by the Appellant for admissions of additional evidences ... stated that the reopening was done on an invalid notice. Besides, the ld.CIT(A) did not take proper cognizance of his request for admission of additional evidences in terms of Rule 46A. 5.1 Considering the entirety of the facts and the circumstances of the case and in the interest

Pawan Kumar Sharma, Noida vs. Income Tax Officer, Noida

In the result, the appeal of the assessee is allowed

ITA 5952/DEL/2024[2011-12]Status: DisposedITAT Delhi12 Nov 2025AY 2011-12

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2011-12 Pawan Kumar Sharma, Vs. Income Tax Officer, E-41, Beta-1, Greater Noida, Income Tax Departmemt. Gautam Budh Nagar, Noida Uttar Pradesh Uttar Pradesh Pan: Abrps9989C (Appellant) (Respondent)

For Appellant: Shri Neeraj Mangla, CA & PraveenFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 139Section 142(1)Section 144Section 147Section 148Section 234ASection 250Section 68

liable to be annulled. 2 2. That the Ld. CIT(A) grossly erred in law and in facts of the case in rejecting admission of additional evidences furnished by the assessee. 3. That the Ld. CIT(A) grossly erred in law and in facts of the case in confirming additions

Prameela Porika, Suryapet vs. ACIT., Circle-7(1), Hyderabad

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

ITA 593/HYD/2025[2017-18]Status: HeardITAT Hyderabad11 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.593/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Smt. Prameela Porika Vs. Acit Suryapet Circle 7(1) Pan:Almpp8561C Suryapet (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate S. Sandhya राज" व "ारा/Revenue By:: Shri Rakesh Chintagumpula, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 11/11/2025 घोषणा की तारीख/Pronouncement: 11/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Smt. Prameela Porika (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, (Nfac), Delhi (“Ld. Cit(A)”) Dated 27.10.2023 For The A.Y 2017-18. Page 1 Of 7

For Appellant: Advocate S. SandhyaFor Respondent: : Shri Rakesh Chintagumpula
Section 270A

properly prosecute the case and therefore substantive submissions and supporting documents could not be filed. The assessee has now filed a petition for admission of additional evidence, containing all relevant documents necessary to establish the claims made in the return of Page

Nikshep Infra Projects, Bangalore vs. Income Tax Officer, Ward-2(1)(3), Bangalore

In the result, appeal filed by the assessee is allowed

ITA 1602/BANG/2025[2023-24]Status: DisposedITAT Bangalore11 Nov 2025AY 2023-24

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2023-24

For Appellant: Shri Sukruth, CAFor Respondent: Shri Subramanian S., Jt.CIT(DR)(ITAT), Bengaluru
Section 250Section 68

accompanying application as additional evidence on its behalf in the interest of justice and equity. 4. The ld. D.R. strongly opposed the admission of additional evidence at this stage. 5. We have heard the rival submissions and perused the materials available on record. On admission of additional evidence, we find

Ravinder Kaur Bhasin, Pritampura vs. ACIT, NFAC

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

ITA 1118/DEL/2025[2015-16]Status: DisposedITAT Delhi11 Nov 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumarassessment Year: 2016-17 Ravinder Kaur Bhasin, Vs Acit/Nfac, 30, Dhudial Apartment, New Delhi Pitam Pura, Delhi – 110 034 Pan No. Anbpb1692H (Appellant) (Respondent)

Section 144BSection 147Section 148Section 234ASection 69

moto interpretation without any explanation asked from the appellant. During the hearing, Ld. AR for the assessee filed an application for admission of additional evidences as per Rule 29 of the ITAT Rules, 1963 and submitted that since the person from whom loan taken were not available in town ... based on suo moto interpretation without any explanation asked from the assessee. Before us, Ld. AR for the assessee filed an application for admission of additional evidences as per Rule 29 of the ITAT Rules, 1963, we find potency in the contention of the Ld. AR that since the person

Leo Bhaginath, Malaparamba, Kozhikode vs. ITO, Ward-1(2), Kozhikode

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

ITA 626/COCH/2025[2016-17]Status: DisposedITAT Cochin10 Nov 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am Assessment Years: 2016-17 Leo Bhagianath .......... Appellant 34/290, Malaparamba, Kozhikode 673009 [Pan: Adtpl7403Q] Vs. The Income Tax Officer, Ward-1(2), Kozhikode .......... Respondent Assessee By: Shri Anand Kumar, V.K, Advocate Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 28.10.2025 Date Of Pronouncement: 10.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 09.07.2025 For Assessment Year (Ay) 2017-18. 2. Brief Facts Of The Case Are That The Appellant Is An Individual Deriving Income As An Advocate. The Return Of Income For Ay 2017- 18 Was Filed On 21.10.2017 Declaring Income Of Rs. 5,50,000/-. Against The Said Return Of Income, The Assessment Was Completed By The Income Tax Officer, Ward 1(2), Kozhikode (Hereinafter Called "The Ao") Vide Order Dated 04.12.2019 Passed U/S. 143(3) Of The Income Tax Act, 1961 (The Act) At A Total Income Of Rs. 42,72,800/-. While Doing So, The Ao Brought To Tax The Credits In The Bank

For Appellant: Shri Anand Kumar, V.K, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)Section 44A

Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 5. The appellant had filed an application seeking admission of additional evidences by stating that these additional evidences could not be produced before the learned lower authorities as the appellant was diagnosed with prostate cancer ... services are rendered by the appellant. 3 Leo Bhagianath 6. On the other hand, the learned Sr. DR had no serious objection for admission the additional evidences. 7. Having considered the rival submissions, I am of the considered opinion that it is a fit case to admit the additional evidences

Anuja Rajesh Bajaj, Chennai vs. ITO, Corporate Ward-1(2), Chennai

In the result, the appeal filed by the assessee is allowed

ITA 2240/CHNY/2025[2010-11]Status: DisposedITAT Chennai10 Nov 2025AY 2010-11

Bench: Shri George George K

For Appellant: Shri Balasubramanian, AdvocateFor Respondent: Shri Vijay Kumar, JCIT
Section 148Section 250Section 271Section 68

remand report from the AO. The assessee had made submissions before the AO during the course of remand proceedings. The petition for admission of additional evidence under Rule 46A of IT Rules, 1962, the details of additional evidence filed before FAA, the submission made before the AO during course

Deputy Commissioner of Income Tax Circle 111, Surat vs. Mukesh Arjanbhai Maniya, Surat

In the result, appeal of revenue is dismissed

ITA 105/SRT/2025[2017-18]Status: DisposedITAT Surat03 Nov 2025AY 2017-18

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.105/Srt/2025 Assessment Year: 2017-18 (Hybrid Hearing) Deputy Commissioner Of Mukesh Arjanbhai Maniya बनाम/ Income Tax, Circle - 1(1)(1), C-303, Afil Tower, L.H. Road, Vs. Surat, Room No.108, 1St Varachha, Surat-395 006 Floor, Aayakar Bhawan, Majura Gate, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Afepm 7227 A (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Sapnesh R Sheth, Ca राज" की ओर से /Respondent By Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 05/08/2025 उद्घोषणा की तारीख/Date Of Pronouncement 03/11/2025

Section 133ASection 139(1)Section 143(3)Section 148Section 250Section 250(2)Section 68

account of unsecured loans u/s 68 of the Act. The revenue has challenged both the merit of deletion as well as admission of additional evidence by CIT(A). In the present case, CIT(A) has examined the audited financial statements of the assessee ... copies of lenders’ balance sheets and ITRs during appellate proceedings, which were considered by the CIT(A). It is settled law that admission of additional evidence at appellate stage is permitted provided the appellate autority is satisfied (i) as to the genuineness and relevance of the evidence (ii) that

Matrix Automotive, Mumbai vs. Ward 41(3)(2), Mumbai

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

ITA 2607/MUM/2025[2016-17]Status: DisposedITAT Mumbai03 Nov 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Anikesh Banerjee () Assessment Year: 2016-2017 Matrix Automotive Income Tax Officer-Ward Shop No. 1,2,3,4 Ground Floor, 41(3)(2), Mumbai Business Classic, Chincholi Vs. Kautilya Bhawan, G Block Bunder Road, Malad West, Bkc, Gilban Area, Bandra Mumbai 400064 Kurla Complex, Bandra East, Mumbai 400051 Pan No. Aaxfm5446P Appellant Respondent

For Appellant: Shri. Dipesh Ruparelia (Virtually appear)For Respondent: Shri Virabhadra Mahajan, Sr. DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 234BSection 234DSection 271(1)(b)Section 271(1)(c)Section 68

give any specific reason for non- submission of documents before AO inspite of noticing comments of AO in the remand report regarding non-admission of additional evidence which shows that appellant has no explanation to offer regarding non submission of above documents before AO. 8.8 It is noticed that appellant ... into ex-parte order against the assessee. In such circumstances, it is sufficient cause by which the assessee was prevented and deserves for admission of additional evidences. Accordingly, we set aside the order of the Ld. CIT(A) on the issue in dispute and restore the matter back

Skechers Sarl, Mumbai vs. The Assistant Commissioner of Income Tax 4(2)(1), Mumbai

In the result the appeal filed by the assessee stands partly

ITA 2028/MUM/2025[2022-23]Status: DisposedITAT Mumbai03 Nov 2025AY 2022-23

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 143(3)Section 144CSection 144C(13)Section 153Section 234BSection 270A

this regard, the the Assessee wishes to invite your Honour's attention to the TRC submitted along with the application for admission of additional evidence dated 11 November 2024 (refer pg. no 204 of the Paper Book (PB) wherein & has been stated that Skechers SARL is subject to the Swiss

Dgs Technical Services Private Limited, Hyderabad vs. DCIT., Circle-8(1), Hyderabad

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 1095/HYD/2024[2021-22]Status: DisposedITAT Hyderabad31 Oct 2025AY 2021-22

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 143(3)Section 144C(5)Section 92C

include the above three companies in the final list of comparable. 30. The Ld. CIT-DR, on the other hand, opposed the admission of additional evidence filed by the assessee and submitted that, the benchmarking analysis for determination of the arm’s length price should be decided on the basis

Stuti Mahendra Hingorani, Mumbai vs. ITO Ward 31(2)(1), Mumbai

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

ITA 5513/MUM/2025[2015-16]Status: DisposedITAT Mumbai31 Oct 2025AY 2015-16

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopalassessment Year : 2015-16 Stuti Mahendra Hingorani, Income Tax Officer, A-305, Regency Lokhanduala Ward-31(2)(1), Complex, Vs. Kautilya Bhavan, Andheri West, C-41 To C-43, G Block, Mumbai-400058. Bandra Kurla Complex, Pan : Adfph3280F Bandra (East), Mumbai-400051. (Appellant) (Respondent)

For Appellant: NONEFor Respondent: Shri Hemanshu Joshi, Sr.DR
Section 144BSection 147

available on record. 5. We find that as part of the Form-35, the assessee has moved an application under Rule 46A for admission of additional evidences and the application as well as the additional evidences were uploaded as part of appeal documentation. However, there is no adjudication in terms ... admission of additional evidences and even on merits of the case. In one of the grounds of appeal raised before us, the assessee has also challenged the order passed by the Ld.CIT(A) for the reason that notices were sent on E-mail ID, which does not belong

Mohammed Husain, Indore vs. Income-Tax Officer, 4(1), Indore

Appeal is allowed for statistical purpose

ITA 761/IND/2024[2017-18]Status: DisposedITAT Indore30 Oct 2025AY 2017-18

Bench: Shri B.M. Biyani

Section 143(2)Section 143(3)Section 144Section 69A

Income-tax Rules, 1962 on which the CIT(A) sought remand-report from AO. In remand report, the AO made objection against admissibility of additional evidences without giving any comments on merit of the evidences. The CIT(A), taking into account the objection raised by AO, rejected assessee’s additional ... raised by AO. 5. Ld. AR next submitted that the assessee has filed an application under Rule 29 of ITAT Rules, 1963 for admission of additional evidences. Further, the evidences are filed in a separate Paper-Book under following index: Page 5 of 8 ‘ Mohammed Husain ITA No. 761/Ind/2024

ACIT, Cir.20(1), Mumbai vs. Girish Shamji Chheda, Mumbai

In the result, the revenue's appeal is dismissed

ITA 3123/MUM/2025[2020-21]Status: DisposedITAT Mumbai30 Oct 2025AY 2020-21

Bench: Shri Pawan Singh & Smt.Renu Jauhri

For Appellant: Shri Fenil Bhatt, AdvFor Respondent: Shri Swapnil Choudhary- Sr. AR
Section 143(3)Section 250Section 36(1)(iii)Section 57Section 68

matter to the ld. AO for examination of evidence and pointed out that the revenue had not raised any such ground against admission of additional evidences by the ld. CIT(A). Further, ld. AR places reliance on the following decisions of Hon'ble Jurisdictional High Court in support ... that neither before the ld. CIT(A) nor in the grounds taken before the Tribunal, ld. AO has raised objection to the admission of additional evidences. He has also submitted the following documents in the form of a paper book before us: “Documentary Evidence to establish of Lender Identity, Creditworthiness

Gaurav Sehgal, Mumbai vs. Dy. Commissioner of Income Tax, Circle 42(1)(1), Mumbai

In the result, the appeal of the assessee for statistical purposes

ITA 1652/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Oct 2025AY 2013-14

Bench: Shri Pawan Singh & Smt. Renu Jauhri

For Appellant: Shri Shekhar GuptaFor Respondent: Shri Swapnil Choudhary- Sr. AR
Section 139Section 142(1)Section 147Section 148Section 250Section 69Section 69C

filing additional evidence under Rule 29 of the ITAT Rules which consists of loan confirmations from 7 parties. Ld. DR has opposed the admission of additional evidence at this stage, pointing out that the assessee did not filed any evidence before the lower authorities as has been discussed in detail ... order of the ld. CIT(A). 6. We have heard the rival submissions on the issue of admission of additional evidence. Since the documents sought to be filed are relevant for decision having direct bearing to the issue under consideration, we hereby admit the additional evidence under Rule

Incomet Tax Officer, Mumbai vs. Deepak Govindbhai Gangani, Mumbai

ITA 5945/MUM/2024[2011]Status: DisposedITAT Mumbai30 Oct 2025

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: NoneFor Respondent: Shri Annavaran Kosuri
Section 144Section 147Section 148

28/06/2024 which was followed by another remand report dated 19/07/2024. In the said remand report, the Learned Assessing Officer objected to the admission of additional evidences being furnished by the Assessee. However, the Learned CIT(A) accepted the contention of Assessee that the Assessee was merely an exit provider ... relevant facts. No reasoning has been given by Learned CIT(A) for admitting the additional evidence even though the Assessing Officer has opposed admission of additional evidence contending that the Assessee had failed to show why additional evidence should be admitted in terms of Rule 46A of the Income

Kajal Batra, Delhi vs. ACIT, Circle-52(1), Delhi

In the result, the appeal of the assessee stands dismissed as above

ITA 2419/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Oct 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 147Section 148Section 151Section 68Section 69A

which document was submitted before the AO and which document was not submitted before the AO. Also, no specific request was made for admission of additional evidences under Rule 46A of the IT Rules. 11.2 During the course of appellate proceedings, the assessee was and to furnish the details along ... submitted that the assessee had filed the detailed submission for the first time on 11.11.2024 before the Ld. CIT(A) and prayed for admission of additional evidence. Hence, the findings of the Ld. CIT(A) that the assessee had not made any request for admission of additional evidence

Dharam Singh, Ghaziabad vs. Income Tax Officer, Ghaziabad

In the result, the Appeal of the Assessee is partly allowed for

ITA 653/DEL/2024[2012-13]Status: DisposedITAT Delhi30 Oct 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 653/Del/2024 (A.Y 2012-13) Dharam Singh V Income Tax Officer 118, Kautilya Apartment, Sector-6, S Ward 1(2), Room No. Vasundhara, Ghaziabad, 230, Cgo Complex-1, Uttar Pradeshpan: Aidps6593H Hapurchungi, Ghaziabad, Uttar Pradesh Appellant Respondent Assessee By None Revenue By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 30/10/2025 Date Of Pronouncement 30/10/2025

Section 143(3)Section 147

time, however those documents have not been filed along with an application under Rule 46 A of the income tax Rules 1962 for admission of additional evidence. However, the Ld. CIT(A) has not 3 Dharam Singh Vs. ITO taken into consideration of those documents as the same ... coupled with application for admission of additional evidence. Considering the issue involved in the present Appeal, with an intention to render substantial justice and in the interest of natural justice, we remand the matter to the file of the Ld. CIT(A) with a liberty to the Assessee to file

Shri Ganesh Nagari Sahakar Patsanstha M. Chiplun Ta. Chiplun, Ratnagiri vs. Income Tax Officer, Ratnagiri

In the result, the appeal filed by the assessee is partly allowed

ITA 1743/PUN/2025[2018-19]Status: DisposedITAT Pune29 Oct 2025AY 2018-19

Bench: Dr.Manish Borad

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Ajitesh Meena
Section 143(3)Section 80PSection 80P(2)(d)

limine without discussing anything on merits of the issues and on the ground that the assessee has not provided plausible explanation for admission of additional evidences. 8. Section 80P(2)(d) of the Act provides that the sum received in respect of any income by way of interest or dividend

Grand Ark Logistics Pvt. Ltd., Chennai vs. DCIT, Corp. Circle-1(1), Chennai

In the result, appeal filed by the assessee is allowed for the

ITA 862/CHNY/2025[2021-22]Status: DisposedITAT Chennai29 Oct 2025AY 2021-22

Bench: Ms. Padmavathy S & Shri Manu Kumar Giri

For Appellant: Shri Arjun Raj, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 133(6)Section 142Section 143(3)Section 191C(6)Section 194C(6)Section 40

without proper application of mind is unjustified and unsustainable. The Id.Counsel contends that the Id.CIT(A) wrongfully rejected the assessee's plea for admission of additional evidence under Rule 46A of the Income Tax Rules, 1962, without appreciating the extraordinary circumstances that led to the non-submission during assessment proceedings