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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

Kailash Chand, Jaipur vs. ITO Ward, Behror

In the result, the appeal of the assessee is allowed

ITA 565/JPR/2024[2012-13]Status: DisposedITAT Jaipur10 Mar 2025AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Judicial Member)

For Appellant: Sh. Mahendra Gargieya, Adv. &For Respondent: Sh. Dinesh Badgujar, Addl. CIT
Section 142(1)Section 144Section 144BSection 147Section 148Section 234A

prayer therein to admit the additional evidence on the merits of the dispute. The prayer of the assessee reads as follows: “PRAYER FOR ADMISSION OF ADDITIONAL EVIDENCES U/R 29 A. In the above case, the humble applicant-assessee humbly prays for admission of following Additional Evidences as under: 1. Copy

Shree Virraj Prabhu Parivar Foundation, Surat vs. CIT(Exemption), Ahmedabad

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

ITA 578/SRT/2024[NA]Status: DisposedITAT Surat07 Mar 2025

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.578/Srt/2024 (Physical Hearing) Shree Virraj Prabhu Parivar Foundation, Vs. The Cit (Exemption), 6-A Ratna Astha Appartment, Opp – Ahmedabad Shree Bharti Maiya School, Vesu, Surat – 395007. "थायीलेखासं./जीआइआरसं./Pan/Gir No: Abkcs0909C (Appellant) (Respondent) Appellant By Shri Deven K. Kapadia, Ca Respondent By Shri Ravi Kant Gupta, Cit-Dr Date Of Hearing 19/02/2025 Date Of Pronouncement 07/03/2025

Section 8Section 80GSection 80G(5)Section 80G(5)(ii)Section 80g(5)

natural justice and causes hardship on the part of the appellant. 6. On the facts and merits of the case appellant craves for admission of additional evidences in the interest of natural justice and equity.” 3. Brief facts of the case are that the assessee filed application in Form No.10AB

Sunkara Kotipalli Naidu, Visakhapatnam vs. The Income Tax Officer, Ward (International Taxation), Visakhapatnam

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

ITA 299/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam07 Mar 2025AY 2016-17

Bench: Shri K. Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.299/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2016-17) Sunkara Kotipalli Naidu V. Income Tax Officer –Ward- Chettupalli Village (International Taxation) Narsipatnam Mandal Income Tax Office Visakhapatnam Infinity Towers Andhra Pradesh – 531116 Sankaramatam Road Visakhapatnam [Pan: Dzdps4163R] Andhra Pradesh,530016 (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 142(1)Section 144(5)Section 147Section 148Section 148ASection 69

rejected the filing of objections which is beyond the stipulated time period of 30 days. 5. Alternatively, assessee also filed a petition for admission of additional evidences as detailed in paper book-2. Ld. Authorised Representative [hereinafter “Ld.AR”] also relied on the decision of the Hon‟ble Telangana High Court ... Telangana), wherein the mandatory faceless procedure as prescribed in the scheme dated 29.03.2022 was not followed. He also pleaded for admission of additional evidences and prayed for remitting the matter back to the file of Ld. AO for fresh consideration of additional evidences and completing the assessment denovo

Biharibhai Gokalbhai Patel, Anand vs. The ACIT, Intl. Taxn., Vadodara

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

ITA 1849/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad07 Mar 2025AY 2016-17

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2016-17 Biharibhai Gokalbhai Patel Acit, Cir.Int-Taxation 17, Sardar Patel Market Vs Vadodara. Dairy Road, Anand 388 001 Gujarat. Pan : Apopp 8402 L (Applicant) (Responent) : Assessee By Shri Darshan Belani, Ar Or Shri S.R Shah, Ca Revenue By : Smt.Malarkodi, R., Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 04/03/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/03/2025

For Respondent: Smt.Malarkodi, R., Sr.DR
Section 143(3)Section 234ASection 250Section 69

report of the AO, the ld.CIT(A) ignored the same and went on to reject the application of the assessee seeking admission of additional evidences filed. He drew our attention to para 11.4 of the CIT(A)’s order wherein one of the reasons given by the Commissioner

Assistant Commissioner of Income-Tax Circle-3(1)(1), Ahmedabad vs. Shri Govind Jairamdas Changlani, Ahmedabad

In the result, the appeal filed by the Revenue is hereby dismissed

ITA 183/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad07 Mar 2025AY 2016-17

Bench: DR. BRR KUMAR (Vice President), Shri T.R. SENTHIL KUMAR (Judicial Member)

Section 143(3)Section 145ASection 68

filed by the assessee. Let us deal with each ground wise the issue before us. 6. Ground No.1 raised by the Revenue is admission of Additional evidences which is contravention of Rule 46A of the Rules. It is undisputed fact that the assessee responded to the notices by filing reply

Sudha Ramani, Chennai vs. Income Tax Officer, Non Corporate Ward 10(3), Chennai

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

ITA 3352/CHNY/2024[2010-11]Status: DisposedITAT Chennai07 Mar 2025AY 2010-11

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.3352/Chny/2024 िनधा"रण वष"/Assessment Year: 2010-11 Sudha Ramani, Vs. The Income Tax Officer, Flat A3, 862, Siddharth Manor, Non Corporate Ward 10(3), Poonamallee High Road, Kilpauk, Chennai. Chennai 600 010. [Pan:Ahepr9857M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Venkata Raman, C.A. ""थ" की ओर से/Respondent By : Shri A. Sasikumar, Cit सुनवाई की तारीख/ Date Of Hearing : 25.02.2025 घोषणा की तारीख /Date Of Pronouncement : 07.03.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 17.10.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2010-11. 2. The Assessee Raised 3 Grounds Of Appeal, Amongst Which, The Only Issue Emanates For Consideration As To Whether The Ld. Cit(A) Is Justified

For Appellant: Shri R. Venkata Raman, C.AFor Respondent: Shri A. Sasikumar, CIT
Section 147Section 251(1)(a)

assessee preferred an appeal before the ld. CIT(A) by filing a petition under Rule 46A of Income Tax Rules, 1962 for admission of additional evidence substantiating the source for investment in the immovable property. The ld. CIT(A) treated the said additional evidences as new evidence and called

M/S. Bsc C&C Jv, New Delhi vs. ACIT, New Delhi

ITA 2963/DEL/2015[2006-07]Status: DisposedITAT Delhi07 Mar 2025AY 2006-07

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshkuldeep, Vs. Cit(A), Village Kastala, Kasmabad, Nfac, New Delhi Tehsil & District Hapur, Uttar Pradesh (Appellant) (Respondent) Pan:Bumpk4317F Assessee By : None Revenue By: Shri Om Prakash, Sr. Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 11/03/2026

For Appellant: NoneFor Respondent: Shri Om Prakash, Sr. DR
Section 144Section 147Section 148Section 151

report from the Learned AO. The Learned AO submitted the remand report on 19-2-2018 wherein the Learned AO objected to the admission of additional evidences as sufficient opportunities were given by him to the assessee during the course of assessment proceedings itself and none of the notices were

Ellora Construction Private Limited, Aurangabad vs. DCIT, Circle-1, Aurangabad

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

ITA 2163/PUN/2024[2018-19]Status: DisposedITAT Pune05 Mar 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Ellora Construction Private Limited Dcit, Circle 1, Cidco Road, Azad Chowk, Vs. Aurangabad Aurangabad-431001 Pan: Aawca7578C (Appellant) (Respondent) Assessee By : Shri Suhas P Bora & Sampada Ingale Department By : Shri Ramnath P Murkunde Date Of Hearing : 04-03-2025 Date Of Pronouncement : 05-03-2025 O R D E R

For Appellant: Shri Suhas P Bora and Sampada IngaleFor Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 36(1)(vii)

submitted that the assessment was completed during the Covid period and the assessee could not furnish certain details. He filed an application for admission of additional evidences under Rule 29 of the ITAT Rules, 1963, the contents of which are as under: “APPLICATION FOR ADMISSION OF ADDITIONAL EVIDENCE UNDER RULE ... appellant in the above-referred appeal, respectfully submits this application under Rule 29 of the Income Tax (Appellate Tribunal) Rules, 1963, seeking admission of additional evidence in support of its contentions in the present appeal. 1. Details of Additional Evidence Being Submitted The following documents which were not produced before

Karnataka Tyre Agencies, Shimoga vs. Income Tax Officer, Ward- 3, Shimoga

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

ITA 1914/BANG/2024[2017-18]Status: DisposedITAT Bangalore05 Mar 2025AY 2017-18

Bench: Shri Waseem Ahmedassessment Years: 2017-18

For Appellant: Shri Hiran Krishnaswamy, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing
Section 142(1)Section 143(3)Section 144

substantial evidence. 9. Furthermore, the ld. CIT(A) did not fully comply with Rule 46A of the Income Tax Rules, which regulates the admission of additional evidence at the appellate stage. 10. Considering these circumstances, I find it appropriate, in the interest of justice and fair-play, to remand

Vipul Lallubhai Kukadiya, Surat vs. ITO, Ward 2(3)(4), Surat

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

ITA 1051/SRT/2024[2016-17]Status: DisposedITAT Surat04 Mar 2025AY 2016-17

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 1051/Srt/2024 (Ay 2016-17) (Physical Court Hearing) Vipul Lallubhai Kukadiya Income Tax Officer, Ward- 126, Gitanagar Society-2, 2(3)(4), Surat, Aayakar Bhavan, बनाम Near Sitaram Chawk, Punagam, Majura Gate, Vs Surat-394 101 Surat-395 001 [Pan : Awppk 7950 P] अपीलाथ"/Appellant ""थ" /Respondent

Section 144Section 254(1)Section 44ASection 69A

account, which clearly shows regular business transaction. The Assessing Officer has not considered periodical withdrawal. Before Ld. CIT(A) assessee filed application for admission of additional evidence in support of various contention, in the statement of fact as well as submission made before Ld. CIT(A). The assessee also filed ... contents of remand report are recorded in para-5.2 of impugned order. In the remand report, Assessing Officer objected for admission of additional evidence by taking plea that assessee has not given any reason for non-compliance of notice during the course of assessment proceedings. And that the assessee does

Jonnalagadda Lakshmi Amruthavalli, Vijayawada vs. Income Tax Officer, Ward-3(1), Vijayawada

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

ITA 514/VIZ/2024[2017-2018]Status: DisposedITAT Visakhapatnam04 Mar 2025AY 2017-2018

Bench: Shri K.Narasimha Chary & Shri Balakrishnan S.

For Appellant: Shri B.Satyanarayana Murthy, ARFor Respondent: Dr. Aparna Villuri,DR
Section 143(3)Section 69A

justified in sustaining the addition of Rs.18,00,000/-. 5. Assessee filed a petition under Rule 29 of Income Tax Appellate Rules for admission of additional evidence before the Tribunal, consisting of assessee’s bank statement with ICICI Madhapur Branch, copy of confirmation letter from husband, copy of Form ... admit the evidences and decide the issue on merits in the interest of justice. 6. Learned DR submitted that assessee’s request for admission of additional evidence at this stage of proceedings is nothing but an afterthought of the assessee. He, therefore, pleaded to uphold the order passed

Mahesh Kumar Choudhary, Kolkata vs. I.T.O., Circle - 36(1), Kolkata

ITA 2192/KOL/2024[2017-2018]Status: DisposedITAT Kolkata03 Mar 2025AY 2017-2018

Bench: Him & Therefore, It Is Mentioned

Section 143(1)Section 143(3)Section 250Section 68

course of appellate proceedings which does not explain the case of the assessee. However, no petition has been filed by the assessee for admission of additional evidence justifying and explaining as to under which Clause of Rule 46A(1), the assessee's case is covered

Ramjee Trading Private Limited, Andheri East, Mumbai vs. DCIT-Circle 13(3)(2), Aayakar Bhavan, Mumbai

ITA 5738/MUM/2024[2012-2013]Status: DisposedITAT Mumbai27 Feb 2025AY 2012-2013

Bench: the CIT(A) since the appeal preferred by the Assessee was dismissed by the CITA(A) has been barred by limitation. It was submitted that the Appellant had moved an application seeking condonation of delay of 167 days in filing appeal before the CIT(A). However, the CIT(A) declined to condone the delay and dismissed the appeal. The Learned Authorised Representative for the Assessee placed reliance on record brief submissions, dated 06/02/2025, and submitted that the Appellant has a good case

For Appellant: Shri Ravindra PoojaryFor Respondent: Shri Rajesh Meshram
Section 143(3)Section 250

Assessment Year 2012-2013. 2. When the appeal was taken for hearing the Learned Authorised Representative for the Assessee moved an application for admission of additional evidence. He submitted that the Assessment Year 2012-13 Assessee was prevented from filing the additional evidence before the CIT(A) since the appeal

Buckman Laboratoires (India) Private Limited, Chennai vs. DCIT, Corp Circle 1(1), Chennai

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

ITA 2451/CHNY/2024[2018-19]Status: DisposedITAT Chennai25 Feb 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Mr. Nageshwara Rao, Advocate (Virtual)For Respondent: Ms.Gauthami Manivasagam, JCIT
Section 143(2)Section 143(3)Section 250Section 37Section 37(1)

either virtual or physical hearing prior to passing of impugned order. The Ld.AR further submitted that assessee has filed a petition for admission of additional evidence in support of allowability of royalty payment for the use of intellectual property right and use of trademark IP . It has also stated that ... been properly appreciated / taken note of by the CIT(A). Moreover, the assessee has filed a petition for admission of additional evidences. The relevant portion of the petition for admission of additional evidence for ready reference is reproduced below:- “The Appellant wishes to draw reference to the additional evidence application

Omprakash Jaiswal, Indore vs. ACIT-1(1), Indore

Appeal is partly allowed for statistical purpose

ITA 443/IND/2024[2017-18]Status: DisposedITAT Indore24 Feb 2025AY 2017-18

Bench: Shri B.M. Biyani & Shri Dinesh Mohan Sinha

Section 143(3)Section 68

merely upheld AO’s order without giving independent adjudication. 13. Before us, the assessee has moved an application dated 24.10.2024 for admission of additional evidences as per Rule 29 of the ITAT Rules, 1963 submitting that the assessee could not obtain ITRs and Bank Statements of lenders since the lenders

Hilton Commodities Pvt. Ltd., Kolkata vs. ITO, Ward-5(3), Kolkata

In the result, the appeal of the revenue is dismissed

ITA 676/KOL/2024[2009-10]Status: DisposedITAT Kolkata24 Feb 2025AY 2009-10

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Hilton Commodities Pvt. Ltd. Ito, Ward 5(3) 9/12, Lal Bazar Street, Aaykar Bhavan, P-7, Mercantile Building, Block-B, Chowringhee Square, Vs. 3Rd Floor, No.10, Kolkata-700069, West Bengal Kolkata-700001, West Bengal (Appellant) (Respondent) Pan No. Aacch1011P Assessee By : Shri Soumitra Choudhury, Ar Revenue By : Shri S Datta, Cit Dr Date Of Hearing: 08.01.2025 Date Of Pronouncement : 24.02.2025

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: Shri S Datta, CIT DR
Section 131Section 143(1)Section 143(2)Section 144Section 147Section 148Section 14ASection 263Section 68

explained in the instant assessment year. The ld. AR also referred to the application filed before the ld. CIT (A) for admission of additional evidences which were wrongly rejected. 09. The ld. AR further contended that considering of the evidences as filed in the paper book which were also available

Sri. T . Rajesh(HUF), Shivamogga vs. Income Tax Officer, Ward-5, Shimoga

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

ITA 2011/BANG/2024[2017-18]Status: DisposedITAT Bangalore24 Feb 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Ms. Sunaina Bhatia, A.RFor Respondent: Sri Ganesh R Gale, Standing counsel for department
Section 143(3)Section 250Section 69A

opinion are very crucial to adjudicate the appeal. However, ld. CIT(A) held that no petition has been filed by the assessee for admission of additional evidence justifying and explaining as to under which clause of rule 46A (1) the assessee’s case is covered

DCIT 1(3)(1), Mumbai, Aayakar Bhavan vs. Ggeopreneur Realty Private Limited, Malad West, Mumbai

In the result, appeal of the revenue is dismissed

ITA 2186/MUM/2024[2014-15]Status: DisposedITAT Mumbai24 Feb 2025AY 2014-15

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Mahaveer Jain & Shobhit Mishra, A/RsFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. D/R
Section 133(6)Section 194JSection 68

towards interest, without following the due procedure laid down in Rule 46A of I.T.Rules, 1961 i.e. without recording the reason for admission of additional evidence as specified in clause 1 of Rule 46A"? 2. Ground No.2" Whether on the facts and in the circumstances of the case ... towards interest, I.T.A. No. 2186 /Mum/2024 2 without considering the remand report of the AO wherein he has objected to admission of additional evidence during appellate stage?" 3. Ground No.3" Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) is justified

Harsha, Jiwana Baghpat vs. Income Tax Officer Ward 1(5) Baraut, Baraut

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

ITA 3527/DEL/2023[2012-13]Status: DisposedITAT Delhi24 Feb 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalincome Tax Officer, Harsha, Ward-1(5), Jiwana Baghpat-250611, Vs. Baraut. Uttar Pradesh. Pan-Adlph3085L (Appellant) (Respondent) Assessee By Shri R.K. Gaur, Ca Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 24/02/2025 Date Of Pronouncement 24/02/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac) Vide Order U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”) Dated 01/11/2023 For The Asst. Year 2012-13. 2. Brief Facts Of The Case Are That The Assessee Is An Individual & During This Year Had Purchased An Agricultural Land Measuring 8.8200 Hectare In Auction Jointly With Five Other Persons At A Total Sale Consideration Of Rs.1,50,82,200/-. Beside This A Sum Of Rs. Harsha Vs. Ito 7,55,000/- Was Paid Towards Stamp Duty Making Total Cost Of Land Was At Rs. 1,65,92,000/-. As The Assessee Has Not Filed Any Return Of Income, The Reassessment Proceedings Were Initiated By Issue Of Notice U/S 148 On 29/03/2019. The Assessee Has Not Attended The Reassessment Proceedings & The Finally The Reassessment Order Was Passed U/S 144/147 Of The Act On 7/12/2019 Wherein The Ao Had Made The Addition Of Rs. 27,65,333/- Being His Share In Investment In Acquisition Of The Property From Undisclosed Sources.

Section 144Section 148Section 250

erred on facts and in law in not allowing the appellant application filed under Rule 46A of the Income Tax Act, 1962 for admission of additional evidences and further erred in not considering the evidences filed before him before adjudicating the appeal of the appellant. “3. On the facts

Unity SMC Joint Venture., Mumbai vs. DCIT-22(1), Mumbai

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

ITA 225/MUM/2024[2014-15]Status: DisposedITAT Mumbai21 Feb 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2014-15 Unity Smc Joint Venture, Dy. Cit-22(1), 1252, Pushpanjali Apartment, Piramal Chambers, Vs. Old Prabhadevi Road, Mumbai-400013. Mumbai-400025. Pan No. Aabfu 9813 C Appellant Respondent

For Appellant: Mr. Ashish Heliwal, CIT-DRFor Respondent: Mr. Apurva Gandhi
Section 40

Rules’), seeking Rules, 1962 (hereinafter referred to as ‘the Rules’), see Rules, 1962 (hereinafter referred to as ‘the Rules’), see admission of additional evidence to substantiate that the payee, admission of additional evidence to substantiate that the payee, admission of additional evidence to substantiate that the payee, M/s Unity Infra ... requested its under the proviso to section 40(a)(ia) of the Act, and requested its admission as additional evidence. The assessee further explained admission as additional evidence. The assessee further explained admission as additional evidence. The assessee further explained the reasons for its inability to furnish the said evidence