“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

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

Nandkumar Yadavrao Tasgaonkar, Mumbai Dadar (West) vs. JCIT, Circle - 16(3), Ayakar Bhavan

Appeal is treated as allowed for statistical purpose

ITA 1726/MUM/2024[2012-2013]Status: DisposedITAT Mumbai24 Sept 2024AY 2012-2013

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: NoneFor Respondent: Shri Ashok Kumar Ambastha

Section 143(3)

response to notice, dated 8/12/2022, Appellant had filed Reply Letter, dated 20/06/2023, whereby the Appellant had also moved an application for admission of additional evidences under Rule 46A of the Income Tax Rules, 1962. It appears that since the time limit to comply with the notice, dated 08/12/2022, lapsed ... dated 07/02/2024, passed by CIT(A) with directions to the Learned CIT(A) to decide the appeal afresh after deciding the application for admission of additional evidence filed by the Appellant and taking into consideration the submission on the Appellant including those filed before the Commissioner of Income Tax (Appeals

Balu Ram, Jaipur vs. Income Tax Officer Ward-7(2), Jaipur

In the result, the appeal filed by the assessee is allowed for statistical purposes with no orders as to costs

ITA 72/JPR/2024[2010-11]Status: DisposedITAT Jaipur23 Sept 2024AY 2010-11

Bench: the AO as well as before the ld. CIT(A) because of the reasons that the copies of these documents could not be obtained by the assessee. The ld AR further submitted that these documents are crucial material for just decision of the appeal. On the contrary, the ld. DR strongly contested this application for leading the additional evidences and submitted that the documents now filed record are not public documents and are self styled documents. Therefore, none of these documents are required

For Appellant: Shri Yogesh Kumar Sharma, AdvFor Respondent: Smt. Monisha Choudhary, Addl. CIT-DR

assessee is admitted for consideration on merit. 3.1 Further at this stage, the ld. AR has moved an application under Rule 29 for admission of additional evidence. Through the present application, the ld. AR has drawn the attention of the Bench to the list of documents of additional documents which

M/S. Pentamedia Graphics Limited, Chennai vs. DCIT Non Corporate Circle-20(1), Chennai

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

ITA 1138/CHNY/2023[2014-15]Status: DisposedITAT Chennai20 Sept 2024AY 2014-15

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.:1138/Chny/2023 िनधा"रण वष"/Assessment Year:2014-15 Pentamedia Graphics Ltd., The Deputy Commissioner Of Income Tax, No.17/7, Thiyagaraya Street, Vs. Non-Corporate Circle – 20(1), T. Nagar, Chennai. Chennai – 600 017. Pan: Aaacp 1647B (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri G. Baskar, Advocate ""यथ" क" ओर से/Respondent By : Ms. R. Anita, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 18.09.2024 घोषणा क" तारीख/Date Of Pronouncement : 20.09.2024 आदेश /O R D E R Per Mahavir Singh: This Appeal By The Assessee Is Arising Out Of The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi In Order No. Itba/Nfac/S/250/2023-24/ 1055115890(1) Dated 14.08.2023. The Assessment Was Framed By The Assistant Commissioner Of Income Tax, Non-Corporate Circle- 20(1), Chennai For The Assessment Year 2014-15 U/S. 143(3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) Vide Order Dated 31.12.2016. 2. At The Outset, The Ld.Counsel For The Assessee Stated That The Cit(A) As Well As The Ao Has Not Allowed Proper Opportunity Of Being Heard & There Is Violation Of Principles Of Natural Justice & For This, The Assessee Has Raised Ground Nos.1.1 To 1.3, Which Read As Under:- “1.1 The Cit(A) Went Wrong In Disposing Of The Appeal In A Summary Manner Without Adverting To The Facts Of The Case & The Submissions Made Before Him In The Proper Perspective.

For Appellant: Shri G. Baskar, AdvocateFor Respondent: Ms. R. Anita, Addl.CIT

Section 143(3)

natural justice and the provisions of the Income-Tax Act. 3. The ld.counsel for the assessee stated that the assessee filed petition for admission of additional evidences under Rule 46 of the Income Tax Rules before CIT(A) vide application dated 03.03.2020 in which, the assessee has filed the following ... which reads as under:- “5. In response to the hearing notice, the assessee vide submission dated 21.04.2023 has submitted petition for admission of additional evidence and filed additional evidences in the form of paper book. Certificate issued by the Central Board of Film Certification for the movie Ali Baba

Neelakanth Kuntoji Basavaraj, Bengaluru vs. Income Tax Officer, Ward-6(2)(1), Bangalore

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

ITA 1157/BANG/2024[2020-21]Status: DisposedITAT Bangalore19 Sept 2024AY 2020-21

Bench: Shri George George K & Shri Waseem Ahmedassessment Year : 2020-21 Shri. Neelakanth Kuntoji Basavaraj, Vs. Ito, Spl B-No.120 1St Stage, Ward – 6(2)(1), Peenya Industrial Estate, Bengaluru. Bengaluru – 560 058. Pan : Agspb 4710 G Appellant Respondent Assessee By : Shri. K. Kiran Kumar, Advocate Revenue By : Shri. V. Parithivel, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 18.09.2024 Date Of Pronouncement : 19.09.2024

For Appellant: Shri. K. Kiran Kumar, AdvocateFor Respondent: Shri. V. Parithivel, JCIT(DR)(ITAT), Bengaluru

Section 115BSection 139(1)Section 142(1)Section 144Section 250Section 68

Aggrieved by the Order of the CIT(A), assessee has filed the present appeal before the Tribunal. Assessee has filed application for admission of additional evidence under Rule 29 of the Income Tax Rules, 1962. The additional evidence submitted by the assessee is affidavit of the assessee’s father stating

The ACIT Central-3, Indore vs. Jarnalbeer Singh Bhatia, Khandwa

ITA 228/IND/2023[2018-19]Status: DisposedITAT Indore18 Sept 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniit(Ss)A Nos.19 To 23/Ind/2023 & Ita No.226/Ind/2023 Ays : 2013-14 To 2018-19 Jarnalbeer Singh Bhatia, Dcit/Acit, बनाम/ Bhatia Transport (Central)-3, Vs. Services, Indore. Old Indore Lines, Pandhana Road, Khandwa (Pan: Aixpb4565C) (Assessee/Appellant) (Revenue/Respondent)

Section 132Section 153ASection 69

Unexplained investment in jewellery u/s 69 2017-18 2 3 Unexplained money in lockers u/s 69A 2018-19 2 4 Admission of additional evidences by CIT(A) 2013-14 1 2014-15 1 2016-17 1 2017-18 1 2018-19 1 5 Unexplained cash credit u/s 68 from ... maintain addition of Rs. 2,75,500/-. The assessee succeeds partly in this issue. Issue No. 4 – Admission of additional evidences by CIT(A): 15. This issue is raised by revenue. The issue shall be relevant at a later stage for adjudication of twin issues i.e. Issue No. 5 [relating

Jarnalbeer Singh Bhatia, Khandwa vs. The ACIT Central-3, Indore

ITA 226/IND/2023[2018-19]Status: DisposedITAT Indore18 Sept 2024AY 2018-19

Section 132Section 153ASection 69

Ace Urban Developers Private Limited, Hyderabad vs. AO, Vijayawada

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

ITA 79/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam13 Sept 2024AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.Nos.79, 118 & 284/Viz/2024 (निर्धारणवर्ा/ Assessment Year: 2016-17, 2018-19 & 2016-17) Ace Urban Developers Private Limited V. The Asst. Cit- Circle-2(1) Module No. A1, A2,A3 Vijayawada – 520002 Quadrant No. 4, 4Thfloor Andhra Pradesh Cyber Tower, Hitech City Madhapur B.O. Sheikpet, Hyderabad-500081, Telangana [Pan: Aanca4001H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Sk Gupta,Ar राजस्व का प्रतततितित्व / Department Represented By : Dr. Satyasai Rath, Sr.Ar

Section 143(3)Section 263Section 68

stated above in ITA No. 79/VIZ/2024 (A.Y. 2016-17). 15. During the first Appellate Proceedings the assessee has submitted a petition seeking admission of additional evidences under Rule 46A of I.T.Rules, while submitting the following evidences: - Page No. 6 I.T.A.Nos.79, 118 & 284/VIZ/2024 ACE URBAN DEVELOPERS PRIVATE LIMITED 1. Bank ... Vijaywada to the ACIT, Circle-2(1), Vijaywada vide his office letter ITA No. 10251/CIT(A)/VJA/2018-19 dated 23.08.2019, calling for comments on admissibility of additional evidence, and merits thereof. The matter was also followed up by way of subsequent reminders, issued on various dates. However, no remand report

Ace Urban Developers Private Limited, Hyderabad vs. Assistant Commissioner of Income Tax, Circle-2(1), Vijayawada

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

ITA 284/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam13 Sept 2024AY 2016-17

Section 143(3)Section 263Section 68

Ace Urban Developers Private Limited, Hyderabad vs. AO, NFAC

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

ITA 118/VIZ/2024[2018-19]Status: DisposedITAT Visakhapatnam13 Sept 2024AY 2018-19

Section 143(3)Section 263Section 68

Gobindram Chandramani Vivek, Bangalore vs. Income Tax Officer - Ward 1(1), Bangalore

In the result, the appeal of the assessee is allowed for statistical purposes, in the manner indicated in this order

ITA 656/BANG/2023[2011-12]Status: DisposedITAT Bangalore13 Sept 2024AY 2011-12

Bench: Mrs. Beena Pillai & Shri Ramit Kochar

For Appellant: Sh. Ashok A Kulkarni, AdvocateFor Respondent: Ms. Neha Sahay, JCIT

Section 139Section 139(1)Section 139(4)Section 143(2)Section 143(3)Section 24Section 54Section 54(2)Section 54F

tune of Rs. 1,49,41,000/- in these two properties at Mavalli. An application dated 06.02.2024(page 190-191/PB) for admission of additional evidences is filed by the assessee under Rule 29 of Income Tax Appellate (Tribunal) Rules, 1963, and prayers were made to admit these additional evidences

Malipeddi Giridhar, Amalapuram vs. The Asstistant Commissioner of Income Tax, Circle-1, Kakinada

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

ITA 169/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam12 Sept 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.169/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2017-18) Malipeddi Giridhar V. The Asst. Cit- Circle-1 Income Tax Office D.No.7-1-20, Mgr Mall Deepthi Towers Tk Street, High School Road Main Road, Kakinada - 533001 East Godavari District – 533201 Andhra Pradesh Andhra Pradesh [Pan: Amhpm0210B] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Gvn Hari, Ar राजस्व का प्रतततितित्व/ Department Represented By : Dr. Satyasai Rath, Sr.Ar

Section 143(2)Section 144Section 37(1)Section 40Section 68

contention of the Ld. Authorised Representative [hereinafter “Ld.AR”] that Ground No. 2 may be considered which is with regard to the admission of additional evidences which is core factor in deciding the appeal of the assessee. Ld.AR submitted that additional evidences were submitted before Ld. CIT(A) through ITBA portal ... wherein evidence is placed at Page No. 48B of the paper book in Item No.18 seeking admission of additional evidences under Rule 46A of I.T. Rules. He pleaded that the Ld. CIT(A) has not considered the submission of additional evidences and has also not called for any remand report

Pawan Kumar, Sonepat vs. ITO Ward-3, Sonipat

In the result, impugned order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 2338/DEL/2023[2011-2012]Status: DisposedITAT Delhi12 Sept 2024AY 2011-2012

Bench: Shri Vikas Awasthyआअसं.2338/िद"ी/2023 (िन.व. 2011-12) Pawan Kumar, Vpo, Khubru The Ganaur, District Sonepat, Haryana 131101 ...... अपीलाथ"/Appellant Pan: Bdhpk-9705-M बनाम Vs. Income Tax Officer, Ward-3, Sonepat ..... "ितवादी/Respondent Haryana अपीलाथ" "ारा/ Appellant By : None "ितवादी"ारा/Respondent By : Ms. Shivani Bansal, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 12/09/2024 घोषणा क" ितिथ/ Date Of Pronouncement : 12/09/2024 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (Hereinafter Referred As To 'The Cit(A)’) Dated 22.06.2023, For Ay 2011-12. 2. The Brief Facts Of The Case As Emanating From Records Are; The Assessee Filed His Return Of Income For Ay 2011-12 Declaring Income Of Rs. 1,15,600/- & Agricultural Income Of Rs. 4,95,700/-. The Assessment For Ay 2011-12 Was Reopened U/S. 148 Of The Income Tax Act, 1961 (Hereinafter Referred As To 'The Act’), On The Ground That The Assessee Has Made Cash Deposits Amounting To Rs. 21,90,000/- + Rs. 8,52,000/-In Savings Bank Account With Oriental Bank Of Commerce, Khubru

For Appellant: NoneFor Respondent: Ms. Shivani Bansal, Sr. DR

Section 142(1)Section 144Section 148

below examined. Undisputedly, the assessee failed to respond to notices issued by the AO and the CIT(A). Except for furnishing application for admission of additional evidences before the CIT(A), the assessee has not made any further submissions before the First Appellate Authority. The CIT(A) without seeking remand

Apni Sahkari Awas Samiti Ltd, Noida vs. ITO, Ward-1(1), Noida

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

ITA 2203/DEL/2023[2011-12]Status: DisposedITAT Delhi12 Sept 2024AY 2011-12

Bench: SHRI VIKAS AWASTHY (Judicial Member)

For Appellant: NoneFor Respondent: Ms. Shivani Bansal, Sr. DR

Section 142(1)Section 144Section 148

adjourned to 12.02.2024. On the said date one Shri Satyajeet Goel, Advocate appeared on behalf of the assessee and filed an application for admission of additional evidences. Thereafter, appeal was adjourned to 09.04.2024. Again none appeared to represent the assessee. On account of non appearance of anyone from assessee

Uttrakhand Samaj, Jaipur vs. The CIT, Exemption, Jaipurthe CIT, Jaipur

In the result, all appeals of the assessee are allowed, for statistical

ITA 778/JPR/2024[NA]Status: DisposedITAT Jaipur11 Sept 2024

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

For Appellant: Sh. K. L. Choudhary, CAFor Respondent: Sh. Arvind Kumar, CIT-DR

Section 12ASection 2(15)Section 80G

Uttrakhand Samaj, Jaipur vs. The CIT, Exemption, Jaipur

In the result, all appeals of the assessee are allowed, for statistical

ITA 777/JPR/2024[NA]Status: DisposedITAT Jaipur11 Sept 2024

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, vk;dj vihy la-@ITA Nos.775 to 778/JP/2024 Uttrakhand Samaj 51/117 Sec 5, Pratap Nagar Sanganer, Jaipur cuke Vs. The CIT, Exemption Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAATU 6874 A vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. K. L. Choudhary, CA jktLo dh vksj ls@ Revenue by : Sh. Arvind Kumar, CIT-DR lquokbZ dh rkjh[k@ Date of Hearing : 20/08/2024 mn?kks"k.kk dh rkjh[k@D

For Appellant: Sh. K. L. Choudhary, CAFor Respondent: Sh. Arvind Kumar, CIT-DR

Section 12ASection 2(15)Section 80G

Uttrakhand Samaj, Jaipur vs. The CIT, Exemption, Jaipur

ITA 776/JPR/2024[NA]Status: DisposedITAT Jaipur11 Sept 2024

For Appellant: Sh. K. L. Choudhary, CAFor Respondent: Sh. Arvind Kumar, CIT-DR

Section 12ASection 2(15)Section 80G

light of the above, the Appellant humbly prays that the Hon'ble Tribunal may be pleased to: - Allow this application for the admission of additional evidence. - Take on record the new evidence as listed above. - Grant any other relief as deemed fit and proper in the interest of justice ... light of the above, the Appellant humbly prays that the Hon'ble Tribunal may be pleased to: - Allow this application for the admission of additional evidence. - Take on record the new evidence as listed above. - Grant any other relief as deemed fit and proper in the interest of justice

Uttrakhand Samaj, Jaipur vs. The CIT, Exemption, Jaipur

In the result, all appeals of the assessee are allowed, for statistical

ITA 775/JPR/2024[NA]Status: DisposedITAT Jaipur11 Sept 2024

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. K. L. Choudhary, CAFor Respondent: Sh. Arvind Kumar, CIT-DR

Section 12ASection 2(15)Section 80G

DCIT, Circle-6, Jaipur, Ncrb vs. Paradise Properties, Sarojni Marg, Jaipur

In the result appeal filed by the revenue is partly allowed

ITA 324/JPR/2024[2017-18]Status: DisposedITAT Jaipur11 Sept 2024AY 2017-18

Bench: The Ld. Cit(A).

For Appellant: Shri S. L. Poddar, AdvFor Respondent: Shri Arvind Kumar, CIT

Section 115BSection 143(3)Section 68

order at page 82 is also relevant which is quoted below: “With reference to above we would like to submit the following- Admissibility of additional evidence under rule 46A of the Income Tax Act, 1961- With reference to above it is submitted that the assessment order for the year under ... acceptable as - i) No adequate opportunity was provided to the AO to give comments on the remand report, before admission of additional evidence under rule 46A of the Act. It is pertinent to mention here that the documents forming the part of the additional evidence were not provided

M/S. Vogue Fabrics, New Delhi vs. DCIT, Panipat

The appeal of the assessee is allowed for statistical purpose

ITA 2889/DEL/2017[2012-13]Status: DisposedITAT Delhi11 Sept 2024AY 2012-13

Bench: Sh. Shamim Yahyash. Laliet Kumarita No. 2889/Del/2017 : Asstt. Year : 2012-13 M/S Vogue Fabrics, Vs Dcit, C/O M/S Rra Taxindia, Circle, Paipat, D-28, South Extension, Part-1, Panipat New Delhi-110049 (Appellant) (Respondent) Pan No. Aabfv1872E Assessee By : Dr. Rakesh Gupta, Adv. & Sh. Deepesh Garg, Adv. Revenue By : Sh. Yogesh Nair, Sr. Dr Date Of Hearing: 10.09.2023 Date Of Pronouncement: 11.09.2023

For Appellant: Dr. Rakesh Gupta, Adv. &For Respondent: Sh. Yogesh Nair, Sr. DR

Section 69A

other.” 3 Vogue Fabrics 3. At the outset, the ld. AR for the assessee has submitted that the assessee filed an application for admission of additional evidence whereby the assessee sought to file the following evidence on record and he drew our attention to following paragraph of application: “This income

Mahajan Awas Foundation, Ahmedabad vs. The CIT(Exemption), Ahmedabad

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

ITA 1102/AHD/2024[NA]Status: DisposedITAT Ahmedabad09 Sept 2024

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.1102/Ahd/2024 "नधा"रण वष" /Assessment Year : N.A. Mahajan Awas Foundation The Cit (Exemption) बनाम/ Fp No.300/23, Kanya Anandnagar-Prahaladnagar Gurukul, Road V/S. Near St.Ann’S School Ahmedabad – 380 015 Nr.Hira Jain Society Ramnagar, Sabarmati Ahmedabad – 380 005 (Gujarat) "थायी लेखा सं./Pan: Aaocm 0161 D अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Deven Kapadia, Ar Revenue By : Shri H. Phani Raju, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 29/08/2024 घोषणा क" तार"ख /Date Of Pronouncement: 10/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: The Present Appeal Has Been Filed By The Assessee, Mahajan Awas Foundation Against The Order Dated 28.03.2024 Passed By The Cit (Exemption), Ahmedabad (Hereinafter Referred To As “Cit(E)”), Rejecting The Assessee’S Application For Approval Under Section 80G(5) Of The Income Tax Act, 1961. Mahajan Awas Foundation Vs. The Cit (E)

For Appellant: Shri Deven Kapadia, ARFor Respondent: Shri H. Phani Raju, CIT-DR

Section 80GSection 80G(5)

justice and causes unnecessary hardship on the part of the appellant. 5. On the facts and merits of the case appellant craves for admission of additional evidences in the interest of natural justice and equity. The appellant craves leave to add, amend, alter, edit, delete, modify or change