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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

Vimlesh Kumar Sharma, Korba vs. Income Tax Officer, Ward-2(1), Bilaspur

In the result, the appeal of the assessee is allowed for statistical purposes in terms of our aforesaid observations

ITA 215/RPR/2022[2017-18]Status: DisposedITAT Raipur20 Oct 2023AY 2017-18

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 215/Rpr/2022 "नधा"रण वष" / Assessment Year : 2017-18 Vimlesh Kumar Sharma 1, Main Road, Opp. Prakash Petrol Pump, Bankimogra, Korba (C.G.)-495447 Pan : Anops4525M .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-2(1), Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(1)Section 250(1)Section 282

reasonable opportunity of being heard to the assessee. 6. The Ld. AR has also filed before us a letter dated 14.08.2023 seeking admission of additional evidence. The Ld. A.R submitted that as the CIT(Appeals) had dismissed his appeal on an ex-parte basis, there was no occasion

Phool Chand, Jaipur vs. ITO, Ward-6(4), Jaipur

In the result the appeal of the assessee is partly allowed

ITA 513/JPR/2023[2009-10]Status: DisposedITAT Jaipur19 Oct 2023AY 2009-10

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. P. C. Parwal (CA)For Respondent: Smt. Monisha Chaudhary (Addl. CIT)
Section 133(6)Section 139Section 142(1)Section 147Section 148Section 54

against Rs.4,830/- declared by the assessee. 3. During the appellate proceedings assessee filed application dt. 26.11.2018 (PB 7-8) for admission of additional evidence under Rule 46A of IT Rules to claim that he be allowed deduction u/s 54 of Rs.12,32,000/- for investment made

Shark Packaging (India) Private Limited, Delhi vs. ITO, Ward-23(1), New Delhi

In the result, the appeal of the assessee for AY 2012-13 is partly allowed only on ground no

ITA 2163/DEL/2022[2008-09]Status: DisposedITAT Delhi17 Oct 2023AY 2008-09

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Mayank Patawari, AdvFor Respondent: Shri Anuj Garg, Addl. CIT
Section 147Section 148Section 253Section 46ASection 68Section 69C

counsel also submitted that the ld. CIT(A) has confirmed the addition by rejecting the detailed explanation and rejecting prayer of admission of additional evidence placed under rule 46A of I.T Rules 1962 whereas the assessee had sufficient cause for which the said evidence was not placed before the Assessing ... other documents before the Assessing Officer. During first appellate proceedings the assessee filed application under rule 46A of the I.T Rules seeking admission of additional evidence pertaining to investor M/s. Forefront Buidcon P Ltd. i.e. copies of name change certificate to M/s. Complete Equity P Ltd dated 14.10.2011, copies

Shark Packaging (India) Pvt Ltd, New Delhi vs. ITO Ward - 23(1), New Delhi

In the result, the appeal of the assessee for AY 2012-13 is partly allowed only on ground no

ITA 8310/DEL/2019[2012-13]Status: DisposedITAT Delhi17 Oct 2023AY 2012-13

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Mayank Patawari, AdvFor Respondent: Shri Anuj Garg, Addl. CIT
Section 147Section 148Section 253Section 46ASection 68Section 69C

counsel also submitted that the ld. CIT(A) has confirmed the addition by rejecting the detailed explanation and rejecting prayer of admission of additional evidence placed under rule 46A of I.T Rules 1962 whereas the assessee had sufficient cause for which the said evidence was not placed before the Assessing ... other documents before the Assessing Officer. During first appellate proceedings the assessee filed application under rule 46A of the I.T Rules seeking admission of additional evidence pertaining to investor M/s. Forefront Buidcon P Ltd. i.e. copies of name change certificate to M/s. Complete Equity P Ltd dated 14.10.2011, copies

Shark Packaging (India) Pvt Ltd, New Delhi vs. ITO Ward - 23(1), New Delhi

In the result, the appeal of the assessee for AY 2012-13 is partly allowed only on ground no

ITA 8309/DEL/2019[2011-12]Status: DisposedITAT Delhi17 Oct 2023AY 2011-12

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Mayank Patawari, AdvFor Respondent: Shri Anuj Garg, Addl. CIT
Section 147Section 148Section 253Section 46ASection 68Section 69C

counsel also submitted that the ld. CIT(A) has confirmed the addition by rejecting the detailed explanation and rejecting prayer of admission of additional evidence placed under rule 46A of I.T Rules 1962 whereas the assessee had sufficient cause for which the said evidence was not placed before the Assessing ... other documents before the Assessing Officer. During first appellate proceedings the assessee filed application under rule 46A of the I.T Rules seeking admission of additional evidence pertaining to investor M/s. Forefront Buidcon P Ltd. i.e. copies of name change certificate to M/s. Complete Equity P Ltd dated 14.10.2011, copies

R.S. Pabbla Constructions Pvt.Ltd., Visakhapatnam vs. The Dy. CIT, Visakhapatnam

In the result, appeal of the assessee is dismissed

ITA 88/VIZ/2017[2014-2015]Status: DisposedITAT Visakhapatnam16 Oct 2023AY 2014-2015

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri G.V.N. Hari, ARFor Respondent: Dr. Satya Sai Rath, CIT-DR
Section 133ASection 143(3)Section 40

above additions, the assessee preferred an appeal before the ld.CIT(A). Before the ld.CIT(A) assessee filed a letter dated 13/12/2016 for admission of additional evidence in the form of confirmation letters for 8 out of 17 labour creditor groups. It was submitted by the assessee that there is sufficient

R.S. Pabbla Constructions Pvt.Ltd., Visakhapatnam vs. The Dy. CIT, Visakhapatnam

In the result, appeal of the assessee is dismissed

ITA 87/VIZ/2017[2013-2014]Status: DisposedITAT Visakhapatnam16 Oct 2023AY 2013-2014

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri G.V.N. Hari, ARFor Respondent: Dr. Satya Sai Rath, CIT-DR
Section 133ASection 143(3)Section 40

above additions, the assessee preferred an appeal before the ld.CIT(A). Before the ld.CIT(A) assessee filed a letter dated 13/12/2016 for admission of additional evidence in the form of confirmation letters for 8 out of 17 labour creditor groups. It was submitted by the assessee that there is sufficient

Lalchand Ramnani, Raipur vs. Income Tax Officer-3(3), Raipur

In the result, the appeal of the assessee is allowed for statistical purposes in terms of the aforesaid observations

ITA 288/RPR/2023[2014-15]Status: DisposedITAT Raipur16 Oct 2023AY 2014-15

Bench: Shri Ravish Soodआयकर अपील सं. / Ita No. 288/Rpr/2023 "नधा"रण वष" / Assessment Year : 2014-15 Lalchand Ramnani New Cloth Market, Pandri, Raipur (C.G.)-492 001 Pan : Acnpr3983J .......अपीलाथ" / Appellant बनाम / V/S.

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(2)Section 143(3)Section 68

Apart from that, it was submitted by the Ld. AR that though the assessee had filed an application for admission of additional evidence under Rule 46A of the Income Tax Rules, 1962, the CIT(Appeals) did not take any cognizance of the same while disposing off the appeal ... adjudicate the matter after considering the assessee’s “written submissions” dated 06.06.2018, and taking a call as regards his request for admission of additional evidence under Rule 46A of the Income Tax Rules, 1962 that was filed before him vide letter dated 05.06.2018. Needless to say, the CIT(Appeals), shall

Aameen Belim, Jodhpur vs. ITO, Ward-2(2), Jodhpur

In the result, the ground no

ITA 571/JODH/2018[2009-10]Status: DisposedITAT Jodhpur12 Oct 2023AY 2009-10

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 124(3)(b)Section 142(1)Section 143(2)Section 143(3)Section 144Section 148Section 250Section 292BSection 69

made any strong objection against the submission of the ld. AR. We accept that the opportunity was denied for the assessee for admission of additional evidence under Rule 46 A of the Income Tax Rule, 1962. Accordingly, the ground no. 2 is duly remanded back to the file

Ganeshram Umanath Nayak, Mumbai vs. ITO 19(2)(3), Mumbai

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

ITA 301/MUM/2014[2009-10]Status: DisposedITAT Mumbai11 Oct 2023AY 2009-10

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Ashwin ChagFor Respondent: Shri Ram Krishna Kedia
Section 133(6)Section 142(1)Section 143(2)Section 250Section 254(1)

evidence, as evident from pages 4-5 of the impugned order. However, the learned CIT(A) rejected the prayer of the assessee for admission of additional evidence under Rule 46A of the Income Tax Rules, 1962. As per the assessee, all these documents were with his wife

M/S Citygold Education Research Ltd, Mumbai vs. DCIT, Central Circle 2-4, Mumbai

In the result, appeals for A

ITA 2266/MUM/2023[2017-18]Status: DisposedITAT Mumbai10 Oct 2023AY 2017-18

Bench: Shri Kuldip Singh () & Ms. Padmavathy S. ()

Section 132Section 143(3)Section 153ASection 37(1)

additional evidence with regard to the advances which have been disallowed under section 37(1) by the Assessing Officer and prayed for the admission of additional evidence. The Ld.AR submitted that the additional evidence go to substantiate the claim of the assessee with regard to the disallowances made and, therefore ... that the additional evidences be admitted and the issue be adjudicated on merits. 18. The Ld.DR, on the other hand, vehemently opposed the admission of additional evidence and prayed that the order of CIT(A) be uphled. 19. We heard the parties and perused the material on record. With regard

Citygold Education Reserch Limited, Mumbai vs. Deputy Commissioner of Income Tax Central Circle--2(4), Mumbai

In the result, appeals for A

ITA 1700/MUM/2023[2019-2020]Status: DisposedITAT Mumbai10 Oct 2023AY 2019-2020

Bench: Shri Kuldip Singh () & Ms. Padmavathy S. ()

Section 132Section 143(3)Section 153ASection 37(1)

additional evidence with regard to the advances which have been disallowed under section 37(1) by the Assessing Officer and prayed for the admission of additional evidence. The Ld.AR submitted that the additional evidence go to substantiate the claim of the assessee with regard to the disallowances made and, therefore ... that the additional evidences be admitted and the issue be adjudicated on merits. 18. The Ld.DR, on the other hand, vehemently opposed the admission of additional evidence and prayed that the order of CIT(A) be uphled. 19. We heard the parties and perused the material on record. With regard

Citygold Education Research Limited, Mumbai vs. DCIT Central Circle 2(4), Mumbai

In the result, appeals for A

ITA 1699/MUM/2023[2016-17]Status: DisposedITAT Mumbai10 Oct 2023AY 2016-17

Bench: Shri Kuldip Singh () & Ms. Padmavathy S. ()

Section 132Section 143(3)Section 153ASection 37(1)

additional evidence with regard to the advances which have been disallowed under section 37(1) by the Assessing Officer and prayed for the admission of additional evidence. The Ld.AR submitted that the additional evidence go to substantiate the claim of the assessee with regard to the disallowances made and, therefore ... that the additional evidences be admitted and the issue be adjudicated on merits. 18. The Ld.DR, on the other hand, vehemently opposed the admission of additional evidence and prayed that the order of CIT(A) be uphled. 19. We heard the parties and perused the material on record. With regard

Mahesh Prasad Singh, Ambikapur vs. Principal Commissioner of Income Tax, Raipur-1, Raipur

In the result, appeal of the assessee is dismissed in terms of our aforesaid observations

ITA 196/RPR/2022[2011-12]Status: DisposedITAT Raipur10 Oct 2023AY 2011-12

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.196/Rpr/2022 "नधा"रण वष" /Assessment Year: 2011-12 Mahesh Prasad Singh Vs The Pr. Commissioner Of Income Tax, Vidyanagar, Sector-3, Raipur-1 Beside Sant Harkewal School, Ambikapur (C.G.)-497 001 Pan: Bbvps9072H (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri R.B Doshi, Ca राज"व क" ओर से /Revenue By : Shri Debashis Lahiri, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 26.09.2023 घोषणा क" तार"ख/Date Of Pronouncement : 10/10/2023 आदेश / O R D E R Per Arun Khodpia, Am : The Captioned Appeal Is Filed By The Assessee Against The Order Passed By The Ld. Pr. Commissioner Of Income Tax, National Faceless Appeal Centre (Nfac), Delhi, Dated 18.03.2023 U/S 263 Of The Income Tax Act, 1961 (For Short ‘The Act’) For Ay 2011-12. The Grounds Of The Appeal Raised By The Assessee Are As Under: “1. Ld. Pr. Cit Erred In Invoking The Provisions Of Sec. 263 & In Setting Aside The Assessment Order For Fresh Enquiry. Order Passed U/S 263 Is Unsustainable & Is Passed Without Properly Appreciating The Facts & Evidences On Record. The Assessment Order Is Neither Erroneous Nor Prejudicial To The Interest Of Revenue. 2. The Appellant Reserves The Right To Add, Amend Or Modify Any Of The Ground/S Of Appeal.”

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri Debashis Lahiri, CIT-DR
Section 139(1)Section 143(3)Section 263Section 44A

bank account (page no. 59). The deposits in the bank account are covered by the turnover declared by the assessee. 4. Request for admission of additional evidence u/r 29 of 1TAT Rules, 1963 The evidence referred to in para no. 2(vi) & 3(ii) above is additional evidence

Delphi Automotive Systems (P) Ltd, New Delhi vs. Deputy Commissioner of Income-Tax, New Delhi

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

ITA 1361/DEL/2015[2010-11]Status: DisposedITAT Delhi09 Oct 2023AY 2010-11

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaaptive Components India P. Ltd, Vs. Deputy Commissioner (Formerly Known As Delphi Of Income-Tax, Automotive Systems P. Ltd), Circle-7(1), P-24, Green Park Extension, New Delhi South Delhi, New Delhi-110016 (Appellant) (Respondent) Pan:Aaacd0226E

For Appellant: Sh. Neeraj Jain, AdvFor Respondent: Sh. Rajesh Kumar, CIT DR
Section 143(3)Section 144CSection 92CSection 92C(2)

committed calculation mistake while working out the imputation of interest on outstanding receivables. 21.7. Per contra, the ld DR vehemently opposed the admission of additional evidences filed by the assessee in as much as no sufficient cause has been shown by the assessee in its application for admission of those

Saloni Singhal Khandelwal, Delhi vs. ACIT, Circle 67(1), New Delhi

In the result, the appeal of the assessee is dismissed

ITA 999/DEL/2023[2018-19]Status: DisposedITAT Delhi05 Oct 2023AY 2018-19

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Shri KVS Gupta, AdvFor Respondent: Shri Anuj Garg, Sr.DR
Section 143(1)Section 143(1)(a)Section 154Section 193(9)Section 199

aggrieved, the assessee preferred appeal before the Tribunal. 8. In the course of hearing before the Tribunal, the assessee moved an application for admission of additional evidences under Rule 29 of the Income Tax (Appellate Tribunal) Rules vide letter dated 28.08.2023. The contract showing terms and conditions of employment

Assistant Commissioner of Income Tax, Circle -2(1)(1), Surat vs. Manish Sumatilal Shah, Mumbai

In the result, the grounds of appeal raised by the revenue are dismissed

ITA 382/SRT/2023[2017-18]Status: DisposedITAT Surat04 Oct 2023AY 2017-18

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Virtual Hearing) A.C.I.T., Manish Sumatilal Shah, Circle- 2(1)(1), 401, 4Th Floor, South Ridge Road, Vs. Surat. Mumbai-400006. Pan No. Adrps 1088 E Appellant/ Respondent Respondent/ Assessee

Section 254(1)Section 54F

erred in deleting the addition without appreciating the facts that during the course of assessment proceedings the assessee was provided adequate opportunities and admission of additional evidences without providing any opportunity to the AO resulted in violation of Rule 46A of I.T. Rules. 4. On the basis of the facts

Narender Rao, Gurgaon vs. ITO, Gurgaon

The appeal is allowed for statistical purposes and the issue on merits is restored to the files of Ld

ITA 137/DEL/2017[2007-08]Status: HeardITAT Delhi03 Oct 2023AY 2007-08

Bench: Sh. M. Balaganesh & Sh.Anubhav Sharma

Section 147Section 148

justice required giving opportunity to assessee, which Ld. CIT(A) filed to ensure, accordingly the 137/Del/2017 grounds raised in regard to non-admission of additional evidence deserve to be allowed. 7. Consequently, the appeal is allowed for statistical purposes and the issue on merits is restored to the files

M/S. Hughes Network Systems India Ltd., New Delhi vs. DCIT, New Delhi

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

ITA 3493/DEL/2017[2009-10]Status: DisposedITAT Delhi29 Sept 2023AY 2009-10

Bench: Shri Chandra Mohan Garg & Dr. B.R.R. Kumarassessment Year: 2009-10 M/S. Hughes Network Systems India The Dcit, Circle 12(1), C.R Building Ltd., New Delhi 1, Shivji Marg, Westend Greens, Nh-8, Vs. New Delhi 110037 Pan Aaach 3025 R (Appellant) (Respondent) For Assessee: Shri Neeraj Jain, Adv. For Revenue : Shri Krishna Kr. Mishra, Sr. Dr Date Of Hearing : 25.09.2023 Date Of Pronouncement : 29.09.2023 Order Per Chandra Mohan Garg, J.M. This Appeal Has Been Filed Against The Order Of Cit(A)-16, New Delhi Dated 03.03.2017 For A.Y. 2009-10. 2. The Grounds Have Been Raised By The Assessee Are As Follows:- 1. That The Commissioner Of Income Tax (Appeals) ['Cit(A)'] Erred On Facts & In Law In Confirming Disallowance Of Miscellaneous Expenses Amounting To Rs. 95,444 Allegedly On The Ground That The Appellant Has Failed To Furnish Any Details & Provide Any Justification Thereof. 2., That The Cit(A) Erred On Facts & In Law In Confirming Disallowance Of Deduction Of Bad Debts Written Off Amounting To Rs.22,08,292 Allegedly On The Ground That The Appellant Has Failed To Provide Details To Confirm That Such Debt Was Taken In Account While Computing The Income Of Previous Year(S). 3. That The Cit(A) Erred On Facts & In Law In Confirming Disallowance Of Legal & Professional Expenditure Amounting To Rs.9,26,123 Allegedly On The Ground That The Appellant Has Failed To Furnish Any Evidence During The Course Of Hearing. 4. That The Cit(A) Erred On Facts & In Law In Disallowing Bad Debts Written Off, Miscellaneous Expenses & Legal & Professional Expenses Without Appreciating That The Accounts Of The Appellant Are Duly Audited By The Statutory Auditors, Tax Auditors & Cost Auditors & It Was Observed In Their Reports That The Books Of Accounts Of The Appellant Were Duly Supported By Necessary Supporting Papers.

For Appellant: Shri Neeraj Jain, AdvFor Respondent: Shri Krishna Kr. Mishra, Sr. DR

observed in their reports that the books of accounts of the appellant were duly supported by necessary supporting papers. Application of assessee for admission of additional evidence under Rule 29 of the Income-Tax (Appellate Tribunal) Rules, 1963. 3. The ld. counsel of assessee submitted that in connection with ground ... entry therefore the additional evidence may kindly be admitted for consideration. 4. Replying to the above the ld. Senior DR oppose to the admission of additional evidence and at the same time, in all fairness, he submitted that the Department has no serious objection if it is found just

Nirmaan Rmbs Trust Series I 2015, Mumbai vs. Dy.Commissioner of Income Tax (TDS)2, Mumbai

In the result, all appeals by the assessee are allowed for statistical purposes

ITA 3231/MUM/2022[2017-18]Status: DisposedITAT Mumbai28 Sept 2023AY 2017-18

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Percy Pardiwala a/wFor Respondent: Shri Ashok Kumar Ambastha
Section 139Section 194LSection 201Section 201(1)Section 250

support of its submission that the deductee has already paid taxes on the income received from the assessee, by way of application seeking admission of additional evidence in these appeals. In the application, the assessee submitted that there were technical issues on the portal and therefore the utility to file