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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

Vasudhevan Muralidharan, Erode vs. ITO, Ward-1(1), Erode

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

ITA 1980/CHNY/2025[2018-19]Status: DisposedITAT Chennai18 Sept 2025AY 2018-19

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1980/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 Shri Vasudhevan The Income Tax Officer, Muralidharan, Vs. Ward 1(1), 25, Bangalore Ayyengar Bakery, Erode 1St Street, Varnapuram, Bhavani – 638 302. Pan: Bnrpm 8315H (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri T.S.Lakshmi Venkataraman, F.C.A ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam,Jcit सुनवाई क" तारीख/Date Of Hearing : 16.09.2025 घोषणा क" तारीख/Date Of Pronouncement : 18.09.2025

For Appellant: Shri T.S.Lakshmi VenkataramanFor Respondent: Ms. Gouthami Manivasagam,JCIT
Section 115BSection 142(1)Section 143(2)Section 143(3)Section 250Section 54FSection 68

present appeal before the Tribunal. The assessee has filed a petition under Rule 29 of the Income Tax Appellate Tribunal Rules, 1963 for admission of additional evidence. The additional evidence that is sought to be admitted is copy of patta, chitta and adangal extracts to establish that lands sold ... extent of Rs.68,50,000/-. The assessee has filed a petition under Rule 29 of the Income Tax Appellate Rules, 1963 for admission of additional evidence. The additional evidence is with regard to documents to show that the lands sold are agricultural lands and are not liable for capital gains

Papi Reddy Ankannagari, Hyderabad vs. DCIT., Circle Circle-3(3), Hyderabad

In the result, the appeal of the assessee in ITA

ITA 1312/HYD/2024[2019-20]Status: DisposedITAT Hyderabad12 Sept 2025AY 2019-20

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1309 To 1312/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2019-20) Shri Papi Reddy Ankannagari, Dy. Commissioner Of Income Vs. Hyderabad. Tax, Pan: Adopa4689A Central Circle 3(3), Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S. Rama Rao, Advocate रधजस् व द्वधरध/Revenue By: Shri Gurpreet Singh, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 02/09/2025 घोर्णध की तधरीख/Pronouncement: 12/09/2025 आदेश/Order Per Bench : These Appeals Are Filed By Shri Papi Reddy Ankannagari (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Hyderabad-11 (“Ld. Cit(A)”), Dated 28.11.2024, 02.12.2024, 29.11.2024 & 28.11.2024 Respectively For The A.Y. 2019-20. Since These Appeals Are Related To The Same Assessee & For The Same A.Y. 2019-20, They

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri Gurpreet Singh, SR-DR
Section 132ASection 143(2)Section 147Section 148Section 68Section 69A

properly respond before the lower authorities. Thus, the ITA Nos.1309 to 1312/Hyd/2024 5 orders were passed ex parte. He therefore prayed for admission of additional evidence now filed before the Tribunal. 6. The Ld. AR submitted that, three issues were involved in the appeal of the assessee i.e. (a) Addition

Papi Reddy Ankannagari, Hyderabad vs. DCIT., Central Circle-3(3), Hyderabad

In the result, the appeal of the assessee in ITA

ITA 1311/HYD/2024[2019-20]Status: DisposedITAT Hyderabad12 Sept 2025AY 2019-20

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1309 To 1312/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2019-20) Shri Papi Reddy Ankannagari, Dy. Commissioner Of Income Vs. Hyderabad. Tax, Pan: Adopa4689A Central Circle 3(3), Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S. Rama Rao, Advocate रधजस् व द्वधरध/Revenue By: Shri Gurpreet Singh, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 02/09/2025 घोर्णध की तधरीख/Pronouncement: 12/09/2025 आदेश/Order Per Bench : These Appeals Are Filed By Shri Papi Reddy Ankannagari (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Hyderabad-11 (“Ld. Cit(A)”), Dated 28.11.2024, 02.12.2024, 29.11.2024 & 28.11.2024 Respectively For The A.Y. 2019-20. Since These Appeals Are Related To The Same Assessee & For The Same A.Y. 2019-20, They

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri Gurpreet Singh, SR-DR
Section 132ASection 143(2)Section 147Section 148Section 68Section 69A

properly respond before the lower authorities. Thus, the ITA Nos.1309 to 1312/Hyd/2024 5 orders were passed ex parte. He therefore prayed for admission of additional evidence now filed before the Tribunal. 6. The Ld. AR submitted that, three issues were involved in the appeal of the assessee i.e. (a) Addition

Papi Reddy Ankannagari, Hyderabad vs. DCIT., Central Circle-3(3), Hyderabad

In the result, the appeal of the assessee in ITA

ITA 1310/HYD/2024[2019-20]Status: DisposedITAT Hyderabad12 Sept 2025AY 2019-20

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1309 To 1312/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2019-20) Shri Papi Reddy Ankannagari, Dy. Commissioner Of Income Vs. Hyderabad. Tax, Pan: Adopa4689A Central Circle 3(3), Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S. Rama Rao, Advocate रधजस् व द्वधरध/Revenue By: Shri Gurpreet Singh, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 02/09/2025 घोर्णध की तधरीख/Pronouncement: 12/09/2025 आदेश/Order Per Bench : These Appeals Are Filed By Shri Papi Reddy Ankannagari (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Hyderabad-11 (“Ld. Cit(A)”), Dated 28.11.2024, 02.12.2024, 29.11.2024 & 28.11.2024 Respectively For The A.Y. 2019-20. Since These Appeals Are Related To The Same Assessee & For The Same A.Y. 2019-20, They

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri Gurpreet Singh, SR-DR
Section 132ASection 143(2)Section 147Section 148Section 68Section 69A

properly respond before the lower authorities. Thus, the ITA Nos.1309 to 1312/Hyd/2024 5 orders were passed ex parte. He therefore prayed for admission of additional evidence now filed before the Tribunal. 6. The Ld. AR submitted that, three issues were involved in the appeal of the assessee i.e. (a) Addition

Papi Reddy Ankannagari, Hyderabad vs. DCIT., Central Circle-3(3), Hyderabad

In the result, the appeal of the assessee in ITA

ITA 1309/HYD/2024[2019-20]Status: DisposedITAT Hyderabad12 Sept 2025AY 2019-20

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1309 To 1312/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2019-20) Shri Papi Reddy Ankannagari, Dy. Commissioner Of Income Vs. Hyderabad. Tax, Pan: Adopa4689A Central Circle 3(3), Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S. Rama Rao, Advocate रधजस् व द्वधरध/Revenue By: Shri Gurpreet Singh, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 02/09/2025 घोर्णध की तधरीख/Pronouncement: 12/09/2025 आदेश/Order Per Bench : These Appeals Are Filed By Shri Papi Reddy Ankannagari (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Hyderabad-11 (“Ld. Cit(A)”), Dated 28.11.2024, 02.12.2024, 29.11.2024 & 28.11.2024 Respectively For The A.Y. 2019-20. Since These Appeals Are Related To The Same Assessee & For The Same A.Y. 2019-20, They

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri Gurpreet Singh, SR-DR
Section 132ASection 143(2)Section 147Section 148Section 68Section 69A

properly respond before the lower authorities. Thus, the ITA Nos.1309 to 1312/Hyd/2024 5 orders were passed ex parte. He therefore prayed for admission of additional evidence now filed before the Tribunal. 6. The Ld. AR submitted that, three issues were involved in the appeal of the assessee i.e. (a) Addition