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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

M/S Denso Kirloskar Industries Pvt.Ltd., Bangalore vs. Assistant Commissioner of Income-Tax, Bangalore

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

ITA 73/BANG/2017[2012-13]Status: DisposedITAT Bangalore20 Jul 2022AY 2012-13

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri V.S. Chakrapani, CIT(DR)(ITAT), Bengaluru

additional evidence supporting its claim for adjustment towards Foreign Exchange Fluctuation and Customs Duty (Ground 3, 4 and 5) . The ld.AR prayed for admission of additional evidences before the Tribunal as these evidences when considered would substantiate the claim of the assessee that the international transactions of the assessee

Dr. Sheela Puttabuddi, Bangalore vs. Income Tax Officer, Ward- 3(3)(5), Bangalore

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

ITA 293/BANG/2020[2015-16]Status: DisposedITAT Bangalore19 Jul 2022AY 2015-16

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Sri.Ravi Shankar, AdvoicateFor Respondent: Sri.Sankar Ganesh K, JCIT-DR
Section 143(2)Section 54

claims related to Section 54 of the Act. Since the ground of appeal sought to be adjudicated itself does not exist, so the admission of additional evidence on such an issue does not arise. Considering above the additional evidence as submitted by the appellant is not admitted.” 6. Aggrieved ... Dr.Sheela Puttabuddi. of total income and acknowledgement of filing of return for the relevant assessment year 2015-2016, copy of the application for admission of additional evidence under Rule 46A, copy of the sale deed of the new asset dated 23.03.2018, computation of capital gains filed before the A.O. during

Leila Advani, Mumbai vs. ACIT - 16(2), Mumbai

In the result, appeal of the revenue is dismissed

ITA 2270/MUM/2016[2011-12]Status: DisposedITAT Mumbai18 Jul 2022AY 2011-12
For Appellant: Sh. Tapas MishraFor Respondent: Smt. Shailja Rai, CIT-DR
Section 143Section 143(2)Section 45(5)(b)Section 48Section 48(1)Section 54F

Meher Rusi Dalal. Pursuant to directions from the Bench on 22nd July 2021, the assessee had submitted, vide application of for admission of additional evidence dated 05.10.2021, a compilation of correspondence between Kishore Mansukhani and the advocates and assessees. These show the extent of involvement of Mr. Mansukhani

Mr.Rahil Mahesh Kumar Nizamuddin, Bangalore vs. Deputy Commissioner of Income Tax (International Taxation) Circle-1(2), Bangalore

In the result, the appeal of the assessee is partly allowed

ITA 892/BANG/2019[2014-15]Status: DisposedITAT Bangalore18 Jul 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2014-15

For Appellant: Shri K.Y. Ningoji Rao, A.RFor Respondent: Shri V.S. Chakrapani, D.R
Section 48Section 54FSection 55A

between the assessee and developer regarding property No.123, Infantry Road, Bengaluru” 3. However, at the time of hearing, the assessee not pressed admission of additional evidence. Accordingly, additional evidence are dismissed as not pressed. 4. Ground No.1 is general in nature. Ground Nos.3 & 4 not pressed and accordingly, dismissed

M/S Kable First Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-4(1)(1), Bangalore

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

ITA 1696/BANG/2018[2015-16]Status: DisposedITAT Bangalore18 Jul 2022AY 2015-16

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri Aliasger Rampurwala, CAFor Respondent: Shri Narayana, K.R., Addl.CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 37(1)Section 40Section 4o

Page 6 of 17 additional evidence stating that the lower authorities did not insist upon the same. 10. The ld. DR vehemently opposed admission of additional evidence filed before the Tribunal stating that the assessee was given ample opportunity before the AO and the assessee failed to produce the required ... customer during the previous year 2006-07 relevant to the assessment year 2007-08.” 11. We will first consider the issue of admission of additional evidence. The ld AR submitted the detailed break-up of the unearned revenue along with invoices in the form of additional evidence before

M/S Kable First Private Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle-4(1)(1), Bangalore

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

ITA 1695/BANG/2018[2014-15]Status: DisposedITAT Bangalore18 Jul 2022AY 2014-15

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri Aliasger Rampurwala, CAFor Respondent: Shri Narayana, K.R., Addl.CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 37(1)Section 40Section 4o

Page 6 of 17 additional evidence stating that the lower authorities did not insist upon the same. 10. The ld. DR vehemently opposed admission of additional evidence filed before the Tribunal stating that the assessee was given ample opportunity before the AO and the assessee failed to produce the required ... customer during the previous year 2006-07 relevant to the assessment year 2007-08.” 11. We will first consider the issue of admission of additional evidence. The ld AR submitted the detailed break-up of the unearned revenue along with invoices in the form of additional evidence before

M/S Kable First India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-4(1)(1), Bangalore

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

ITA 1694/BANG/2018[2013-14]Status: DisposedITAT Bangalore18 Jul 2022AY 2013-14

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri Aliasger Rampurwala, CAFor Respondent: Shri Narayana, K.R., Addl.CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 37(1)Section 40Section 4o

Page 6 of 17 additional evidence stating that the lower authorities did not insist upon the same. 10. The ld. DR vehemently opposed admission of additional evidence filed before the Tribunal stating that the assessee was given ample opportunity before the AO and the assessee failed to produce the required ... customer during the previous year 2006-07 relevant to the assessment year 2007-08.” 11. We will first consider the issue of admission of additional evidence. The ld AR submitted the detailed break-up of the unearned revenue along with invoices in the form of additional evidence before

M/S Te Connectivity India Pvt Ltd, Bengaluru vs. Deputy Commissioner of Income Tax, Ltu, Circle-1, Bengaluru

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

ITA 2680/BANG/2017[2013-14]Status: DisposedITAT Bangalore18 Jul 2022AY 2013-14

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri Sumeet Khurana, CAFor Respondent: Shri V.S. Chakrapani, CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 143(3)Section 40Section 92

submitted a detailed report from the AE in the form of additional evidence in a separate PB and prayed for admission of additional evidence. We admit the additional evidence since it goes to the root of the matter. 49. The ld. AR also submitted that if separate benchmarking

M/S Wings Eco Homes (P) Ltd, Mumbai vs. DCIT-11(3)(2), Mumbai

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

ITA 2434/MUM/2019[2011-12]Status: DisposedITAT Mumbai07 Jul 2022AY 2011-12

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadalem/S Wings Eco Homes (P) Vs. Dy. Cit Ltd. Circle-11(3)(2), 110/114, Building No.4 M.K.Road, Mittal Industrial Estate Mumbai-400020. Marol Naka, Andheri (East) Mumabi-400059

For Appellant: Shri Dhaval Shah.ARFor Respondent: Shri Hemant Kumar
Section 143(1)Section 143(2)Section 143(3)Section 68

availability of persons at the address. The assessee has a good case on merits and is filing application for the admission of additional evidence and prayed to consider the additional evidence and allow the assesse appeal. Contra, the Ld. DR supported the order of the CIT(A) and submitted that ... appellate proceedings before the CIT(A) with the details of unsecured loan creditors. The assessee has filed an application for admission of additional evidence on the identity, geninuneness and credit worthiness of the parties by way of ledger account copies, Annual report and Bank statements before the Honble Tribunal

Sri Simhadri Ponnaluru Reddy, Bangalore vs. Deputy Commissioner of Income Tax, Circle - 3(1)(1), Bangalore

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

ITA 1106/BANG/2019[2015-16]Status: DisposedITAT Bangalore05 Jul 2022AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2015-16

For Appellant: Shri Ravi Shankar, A.RFor Respondent: Smt. Priyadarshini Baseganni, D.R
Section 143Section 37Section 41(1)

interest of justice, we admit these additional grounds for adjudication. 4.1 The assessee also filed additional evidences along with petition for admission of additional evidence and submitted that these additional evidences were not filed before the lower authorities on the reason that the details are not pertaining to the impugned ... serious objection on this issue. 4.5 We have heard the rival submissions and perused the materials available on record. On the admission of additional evidences, in our opinion, the additional evidences are very important to decide the issue fairly. Accordingly, these additional evidences are admitted for adjudication. 4.6 Coming

Lake View Hospitality, Mumbai vs. DCIT- CPC, ITO 26(2)(1), Mumbai

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

ITA 213/MUM/2022[2017-18]Status: DisposedITAT Mumbai01 Jul 2022AY 2017-18

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Jitendra Singh, AdvocateFor Respondent: Smt. Smita Nair, Sr. A.R
Section 139(1)Section 143(1)Section 250Section 43B

details of payment of VAT liability along with sample copy of challans, which have been filed before us along with an application seeking admission of additional evidence under Rule 29 of Appellate Tribunal Rules, 1963. Learned AR further submitted that due to COVID related restrictions, office of the assessee ... therefore, necessary details could not be filed before the learned CIT(A). 6. On the other hand, learned Departmental Representative fairly agreed to admission of additional evidence filed by the assessee. 7. We have considered the rival submissions and perused the material available on record. As per the provision

Tata International Ltd ( for Erstwhile Bachi Shoes Ltd), Vellore vs. ACIT Circle 1, Vellore

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

ITA 1523/CHNY/2018[2013-14]Status: DisposedITAT Mumbai30 Jun 2022AY 2013-14

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Tata International Limited V. Acit – Circle – 1 {Erstwhile Bachi Shoes Ltd} No.2, 2Nd Floor No. 147, Sidco Industrial Estate Central Revenue Building Sipcot, Ranipet – 632403 Barracks Cross Street Officers Line, Vellore -632001 (Appellant) (Respondent) Assessee By : Ms. Aastha Shah Department By : Shri Rajesh Damor Date Of Hearing : 02.06.2022 Date Of Pronouncement : 30.06.2022 O R D E R Per S. Rifaur Rahman (Am) 1. This Appeal Is Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)–13, Chennai [Hereinafter In Short “Ld.Cit(A)”] Dated 05.03.2018 For The A.Y. 2013-14. 2. Assessee Has Raised Following Grounds In Its Appeal: - “The Appellant Objects To The Commissioner Of Income Tax (Appeals) [Cit(A)'S Order Dismissing The Appeal Against The Assessment Order, For 2013-14 Aly I) Omitting To Reduce The Adjustments Of Rs. 5,69,560 U/S 145A As Per Letter Dated 25.2.2016;

For Appellant: Ms. Aastha ShahFor Respondent: Shri Rajesh Damor
Section 145ASection 32Section 32(1)(ii)Section 32(1)(iia)Section 40

aforesaid computation and justice rendered.” 3. Before us, at the time of hearing, assessee filed petition along with additional evidences and prayed for admission of additional evidences. Ld.AR submitted that these additional evidences go to the root of the matter, the same may be admitted and remit the same

DCIT 2 (3), Mumbai vs. Tata Sons Ltd, Mumbai

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

ITA 3850/MUM/2014[1990-91]Status: DisposedITAT Mumbai30 Jun 2022AY 1990-91

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bledcit -2(3) V. M/S. Tata Sons Limited Room No. 552, 5Th Floor Bombay House Aayakar Bhavan, M.K. Road 24, Homi Modi Street Mumbai - 400020 Fort, Mumbai - 400001 Pan: Aaact4060A (Appellant) (Respondent) Assessee By : Ms. Aarti Vissanji & Ms. Aastha Shah Department By : Shri B.K. Bagchi Date Of Hearing : 02.06.2022 Date Of Pronouncement : 30.06.2022 O R D E R Per S. Rifaur Rahman (Am) 1. This Appeal Is Filed By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals)–6, Mumbai [Hereinafter In Short “Ld.Cit(A)”] Dated 04.02.2014 For The A.Y. 1990-1991. 2. Revenue Has Raised Following Grounds In Its Appeal: - “1. The Order Of The Cit(A) Is Opposed To Law & Facts Of The Case." 2. "On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit (Appeal) Has Erred In Directing The A.O To Grant The 2 M/S. Tata Sons Limited Double Taxation Relief To The Assessee At Rs.1.00.49,042/- Without Appreciating That Dit Relief Can Only Be Granted When The Income Taxed By Foreign Authority Is Included In The Total Income Of The Assessee. However, In The Present Case Foreign Income Is Not Included In Total Income 3. For These & Other Grounds That May Be Urged At The Time Of Hearing, The Decision Of The Cit(A) May Be Set Aside & That Of The Ao Be Restored.

For Appellant: Ms. Aarti Vissanji &For Respondent: Shri B.K. Bagchi

restored. 3. Before us, at the time of hearing, assessee filed petition along with additional evidences and prayed for admission of additional evidences. Ld.AR submitted that these additional evidences go to the root of the matter, the same may be admitted and remitted the same to the file

Smt. Hemavathi, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle- 1(4), Bangalore

In the result, both the appeals filed by the assessee stands party allowed for statistical purposes

ITA 42/BANG/2021[2012-13]Status: DisposedITAT Bangalore30 Jun 2022AY 2012-13

Bench: Smt. Beena Pillai & Shri. Laxmi Prasad Sahu

For Respondent: Shri Pranav Krishna
Section 153C

assessment proceedings and therefore the same were not could not be submitted even before the Ld.CIT(A). He thus prayed for the admission of additional evidence now filed before this Tribunal. 3. The Ld.DR on the contrary, opposed for the admission of these documents. The Ld.DR in respect

Smt. Hemavathi, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle- 1(4), Bangalore

In the result, both the appeals filed by the assessee stands party allowed for statistical purposes

ITA 41/BANG/2021[2009-10]Status: DisposedITAT Bangalore30 Jun 2022AY 2009-10

Bench: Smt. Beena Pillai & Shri. Laxmi Prasad Sahu

For Respondent: Shri Pranav Krishna
Section 153C

assessment proceedings and therefore the same were not could not be submitted even before the Ld.CIT(A). He thus prayed for the admission of additional evidence now filed before this Tribunal. 3. The Ld.DR on the contrary, opposed for the admission of these documents. The Ld.DR in respect

Smt. Hemavathi, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle- 1(4), Bangalore

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

ITA 40/BANG/2021[2008-09]Status: DisposedITAT Bangalore30 Jun 2022AY 2008-09
For Respondent: Shri Pranav Krishna
Section 153Section 153CSection 234Section 250

assessment proceedings and therefore the same were not could not be submitted even before the Ld.CIT(A). He thus prayed for the admission of additional evidence now filed before this Tribunal. 3. The Ld.DR on the contrary, opposed for the admission of these documents. The Ld.DR in respect

Ibm India Pvt. Ltd., Bangalore vs. DCIT, Bangalore

In the result appeal filed by assessee stands allowed

ITA 1151/BANG/2009[2002-03]Status: DisposedITAT Bangalore30 Jun 2022AY 2002-03

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2002-03 M/S. Ibm India Pvt. Ltd., The Deputy No. 12, Subramanya Commissioner Of Arcade, Income Tax, Bannerghatta Road, Circle 11 (1), Bangalore – 560 029. Bangalore. Vs. Pan: Aaaci4403L Appellant Respondent Assessee By : Shri Sharath Rao, Advocate Revenue By : Shri Vilas V Shinde, Cit Dr Date Of Hearing : 30-06-2022 Date Of Pronouncement : 30-06-2022 Order Per Beena Pillaipresent Appeal Arises Out Of The Dated 3/11/2020 Passed By Hon’Ble Karnataka High Court In Ita No.392/2011. Hon’Ble High Court Admitted The Following Question Of Law Vide Order Dated 28/03/2012: “(I) Whether The Tribunal Was Correct In Holding That Whether The Appellate Authority Were Correct In Holding That Maintenance Of Separate Accounts For Stp Units & Non Stp Units Was Only Directory & Not Mandatory In Accordance With Rbi Conditions, Government Notification & Income Tax Act? (Ii) Whether The Appellate Authority Were Correct In Holding That Payments Made To Sub Contractors Who Have Separately Exported & Have Been Issued Foreign Inward Remittance Certificate & Have Also Claimed 10A Deduction Will Also Be Entitled To Double Deduction Under Section 10A Of The Act In Hands Of The Assessee?

For Appellant: Shri Sharath Rao, AdvocateFor Respondent: Shri Vilas V Shinde, CIT DR
Section 10A

debts that were written off in the books of account as irrecoverable. The assessee vide Application dated 20/06/2022 filed petition for admission of additional evidence, wherein, the bona fide efforts taken by the assessee before writing off the debts to be bad and various ledger accounts have been filed that

Loreal India Pvt. Ltd, Mumbai vs. Addl/Jt/Dy/ACIT/ITO/NFAC, Delhi

In the result, the appeal filed by the assessee for AY 2016-17 is treated as partly allowed

ITA 802/MUM/2022[2017-18]Status: DisposedITAT Mumbai29 Jun 2022AY 2017-18
Section 143(3)Section 144CSection 92C

decision of Tribunal for AY 2014- 15. The ld. AR for the assessee submits that the assessee has also filed an application for admission of additional evidence. The additional evidences furnished by the assessee have direct relevance with the issue under consideration. The lower authorities however, did not give ... through the additional evidences filed by assessee along with the application dated 9 L’Oreal India Private Limited 04.02.2020. In the application for admission of additional evidence the assessee stated that TPO while making T.P. Adjustment made alternative T.P. Adjustment on account of payment of packaging, design cost, training

Dy CIT-Circle-22(1), Mumbai vs. Mr Jamil Ahmed Quireshi, Mumbai

ITA 1202/MUM/2021[2010-11]Status: DisposedITAT Mumbai29 Jun 2022AY 2010-11

Bench: Shri M Balaganesh & Pavan Kumar Gadaledcit, Circle – 22(1), Vs. Mr. Jamil Ahmed Room No. 322, 3Rd Floor, Qureshi Piramal Chambers, Lal 102, Emerland Baug, Parel, Apartment, Near Dadar Mumbai-400012. Shakari Bank, Santacruz (W), Mumbai – 400055. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabpq1063C Appellant .. Respondent Appellant By : Shri S.N.Kabra.Dr Respondent By : Shri Dhaval Jariwala.Ar Date Of Hearing 23.05.2022 Date Of Pronouncement 23.06.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Revenue Has Filed The Appeal Against The Order Of The Commissioner Of Income Tax (Appeals) -32 Mumbai Passed U/S 143(3) & 250 Of The Income Tax Act, 1961. The Revenue Has Raised The Following Grounds Of Appeal.

For Appellant: Shri S.N.Kabra.DRFor Respondent: Shri Dhaval Jariwala.AR
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 69C

appellate proceedings, additional evidence u/s. 46A of the I.T. Rules was submitted vide letter dated 30.07.2014 as under: "Sub: Application for admission of additional evidence under Rule 46A of the I.T. Rules - Shri Jamil Ahmed Qureshi - PAN - AABPQ1063C Under instruction of our above named client we submit as under

L' Oreal India P. Ltd., Mumbai vs. National E-Assessment Centre/ Dy CIT-Circle-7(1)(1), Mumbai

In the result, the appeal filed by the assessee for AY 2016-17 is treated as partly allowed

ITA 1198/MUM/2021[2016-17]Status: DisposedITAT Mumbai29 Jun 2022AY 2016-17
Section 143(3)Section 144CSection 92C

decision of Tribunal for AY 2014- 15. The ld. AR for the assessee submits that the assessee has also filed an application for admission of additional evidence. The additional evidences furnished by the assessee have direct relevance with the issue under consideration. The lower authorities however, did not give ... through the additional evidences filed by assessee along with the application dated 9 L’Oreal India Private Limited 04.02.2020. In the application for admission of additional evidence the assessee stated that TPO while making T.P. Adjustment made alternative T.P. Adjustment on account of payment of packaging, design cost, training