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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

Assistant Commissioner of Income Tax, Agra vs. Chitavalsah Jute Mills Limited, New Delhi

In the result the appeal of the revenue is dismissed

ITA 99/AGR/2025[2012-13]Status: DisposedITAT Agra04 Dec 2025AY 2012-13

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh(Through Virtual Hearing) Acit, Vs. Chitavalasah Jute Mills Ltd, Range-1, 73-74, 201, Sheetala House, Faridabad Nehru Place, New Delhi (Appellant) (Respondent) Pan: Aaccc6834D Assessee By : None Revenue By: Shri Sukesh Kumar Jain, Cit Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 04/12/2025

For Appellant: NoneFor Respondent: Shri Sukesh Kumar Jain, CIT DR
Section 144Section 271D

before the ld CIT(A). Remand reports were sought for from the ld AO. The ld AO in the remand report objected to admission of additional evidences and did not give Chitavalasah Jute Mills Ltd any comment on merits. The ld AO in the remand report admitted the fact that ... without making any enquiry on the evidences submitted by the assessee and by merely objecting to the admission of additional evidences. The ld CIT(A) also took note of the fact that the Tribunal in the first round had clearly directed the additional evidences filed by the assessee

Baldev Singh Bhadoriya, Gwalior vs. ITO-3(2), Gwalior

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

ITA 37/AGR/2023[2015-16]Status: DisposedITAT Agra04 Dec 2025AY 2015-16

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh(Through Virtual Hearing) Smt Kiran Lata Bhadoria, Vs. Income Tax Officer, Ward- L/H Of Late Shri Baldev 3(2), Singh Bhadoria, Gwalior Mig-20, Darpan Colony, 474005, Mp (Appellant) (Respondent) Pan: Ahopb3071D Assessee By : Shri Somil Agarwal, Adv Shri Deepesh Garg, Adv Revenue By: Shri Sukesh Kumar Jain, Cit(Dr) Date Of Hearing 15/09/2025 Date Of Pronouncement 04/12/2025

For Appellant: Shri Somil Agarwal, AdvFor Respondent: Shri Sukesh Kumar Jain, CIT(DR)
Section 143(3)Section 56(2)(vii)

This is enclosed in pages 176 to 177 of the paper book. 8. We find that the Assessee in the petition praying for admission of additional evidences dated 19-05-2025 had duly adduced the reasons for not filing these additional evidences before the lower authorities. We find that these

The Salem Urban Coop Bank Ltd., Salem vs. DCIT, Circle-1(1), Salem

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

ITA 2673/CHNY/2025[2018-19]Status: DisposedITAT Chennai04 Dec 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 133Section 197ASection 197A(2)Section 201(1)Section 251

Income-tax Department and subsequently they have been uploaded, but acknowledgment receipt was not generated by system. The Ld. A.R. also sought admission of additional evidence under Rule 29 of the Income-tax (Appellate Tribunal) Rules, 1963, including the details of Form 15G/15H and evidence showing that the relevant forms

Jaya Rinkubhai Bandukwala, Surat vs. The Income Tax Officer, Ward 3(3)(1) Surat, Surat

ITA 452/SRT/2025[2018-19]Status: DisposedITAT Surat03 Dec 2025AY 2018-19

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.451 & 452/Srt/2025

Section 250Section 272A(1)(d)

vary any of the grounds of appeal." ITA No.451/SRT/2025 3. During the course of hearing, appellant filed an application dated 20.09.2025, seeking admission of additional evidence in the case assessee for AY 2018-19. This additional evidence includes copy of purchase deed dated 14.12.2004 and copy of sale deed dated ... matter and is essential for proper adjudication of the issue in dispute. 4. The Ld. Sr. DR for the revenue opposed the admission of additional evidence, stating that sufficient opportunity had been granted during assessment and appellate proceedings. 5. We have considered the contentions of both the parties and perused

Jaya Rinkubhai Bandukwala, Surat vs. The Income Tax Officer, Ward 3(3)(1) Surat, Surat

In the result, appeal of assessee is partly allowed

ITA 451/SRT/2025[2018-19]Status: DisposedITAT Surat03 Dec 2025AY 2018-19

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.451 & 452/Srt/2025 Assessment Year: (2018-19) (Hybrid Hearing) Jaya Rinkubhai Bandukwala Income Tax Officer, बनाम/ 1/611,Dhatigara Street, Ward -3(3)(1), Surat-395 001 Vs. Timaliyawad, Manpura, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Bbfpb 1989 N (अपीलाथ"/Appellant) (""थ" /Respondent)

Section 250Section 272A(1)(d)

alter or vary any of the grounds of appeal.” 3. During the course of hearing, appellant filed an application dated 20.09.2025, seeking admission of additional evidence in the case assessee for AY 2018-19. This additional evidence includes copy of purchase deed dated 14.12.2004 and copy of sale deed dated ... matter and is essential for proper adjudication of the issue in dispute. 4. The Ld. Sr. DR for the revenue opposed the admission of additional evidence, stating that sufficient opportunity had been granted during assessment and appellate proceedings. 5. We have considered the contentions of both the parties and perused

Kirit Babubhai Jhaveri, Surat vs. ACIT, Circle-2(2), Surat

In the result, the appeal is allowed for statistical purposes, subject to the of cost of Rs

ITA 52/SRT/2024[2015-16]Status: DisposedITAT Surat03 Dec 2025AY 2015-16

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.52/Srt/2024 Assessment Year: 2015-16 (Hybrid Hearing) Kirit Babubhai Jhaveri, Vs. Acit, 22, Zaveri Bungalow, Opp – Circle – 2(2), Meghna Park, City Light Road, Surat Surat – 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabpz4942P (Appellant) (Respondent)

Section 143(3)Section 234ASection 250Section 271(1)(c)Section 54Section 54B

hearing of this appeal or from time to time.” 3. During the course of hearing, appellant filed an application dated 14.04.2025, seeking admission of additional evidence in the case assessee for AY 2015-16. This additional evidence pertains to affidavit obtained by the appellant regarding the purchase of agricultural land ... matter and is essential for proper adjudication of the issue in dispute. 4. The Ld. Sr. DR for the revenue opposed the admission of additional evidence, stating that sufficient opportunity had been granted during assessment and appellate proceedings. 5. We have considered the contentions of both the parties and perused

Viewmore Enclave Pvt. Ltd., Siliguri vs. ITO, Ward 9(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2106/KOL/2025[2012-2013]Status: HeardITAT Kolkata03 Dec 2025AY 2012-2013

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Viewmore Enclave Pvt. Ltd. C/O Subash Agarwal & Ito, Ward 9(1) Associates, Advocates, Siddha Aaykar Bhawan Poorva, 5 Th Floor, Gibson,1, Gibson Lane, Suite P07, Chowringhee Square, Vs. 213, 2Nd Floor, Kolkata-700069, Kolkata-700069, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aadcv9941M Assessee By : Shri Siddharth Agarwal, Ar Revenue By : Shri S.B. Chakraborthy, Dr Date Of Hearing: 18.11.2025 Date Of Pronouncement: 03.12.2025

For Appellant: Shri Siddharth Agarwal, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 131Section 68

these evidences filed by the assessee under Rule 46A of the Rules, by stating that the assessee has not moved any application for admission of additional evidences, whereas as a matter of fact all these evidences were not in the nature of additional evidences and were available before the learned

Golden Realty, Mumbai vs. Income Tax Officer 19(1)(3), Matru Mandir Mumbai

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

ITA 1770/MUM/2024[2017-2018]Status: DisposedITAT Mumbai03 Dec 2025AY 2017-2018

Bench: Justice (Retd.) C. V. Bhadang & Shri Prabhash Shankargolden Realty V/S. Income Tax Officer– 19(1)(3), 617, 6Th Floor, Tardeo Air बनाम 220, 2Nd Floor, Matru Condition Market, Tardeo Mandir, Tardeo Road, Road, Mumbai – 400 034, Mumbai – 400 007, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaifg8857D Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Bhupendra Shah, ARFor Respondent: Shri Swapnil Choudhary, (Sr. DR)
Section 143(3)Section 68

amply settled and clear that this Tribunal can admit additional evidence in terms of Rule 29 of ITAT Rules if the receipt or admission of additional evidence is vital and essential for the purpose of consideration of the subject-matter of the appeal and arrive at a final and ultimate

Santosh Kumar, Surguja vs. ITO - 1 Ambikapur, Ambikapur

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

ITA 671/RPR/2025[2013-14]Status: DisposedITAT Raipur02 Dec 2025AY 2013-14

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.671/Rpr/2025 "नधा"रण वष" /Assessment Year : 2013-14

For Appellant: Shri G.S. Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 144Section 249(2)Section 249(3)

/NFAC had dismissed the appeal on the ground of limitation. Before me, it was pleaded by the Ld. Counsel for the assessee for admission of additional evidences under Rule 29 of the ITAT Rules, 1963 which I have granted permission to the Ld. Counsel and he had accordingly filed

Airport Retail Private Limited, Mumbai vs. Assistant Commissioner of Income-Tax, Circle 12(1)(1), Mumbai

ITA 3198/MUM/2025[2017-18]Status: DisposedITAT Mumbai02 Dec 2025AY 2017-18

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Rajesh Kumar Yadav,CIT-DR
Section 115BSection 234Section 234BSection 250Section 271ASection 68

that the AO did not give sufficient time for the assessee to file the details called for and prayed for admission of additional evidence and the CIT(A) called for a remand report from the AO with regard to the various details filed by the assessee. The assessee submitted

Mumbai Cricket Association, Mumbai vs. Commissioner of Income Tax (Exemptions), Mumbai

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

ITA 1257/MUM/2025[2024-2025]Status: DisposedITAT Mumbai02 Dec 2025AY 2024-2025

Bench: Shri Sandeep Gosain& Shri Prabhash Shankar

Section 11(1)(c)Section 12ASection 12A(1)(ac)Section 2(15)

application for leading additional evidence has been filed by the appellant, the contends of which are reproduced herein below: Sub: Application for admission of additional evidence under rule 29 of the Income-Tax (Appellate Tribunal) Rules 1963 in the case of Mumbai Cricket Association ITA No. ITA 1257/MUM/2025

Fuji Electric India Private Limited, Chennai vs. Deputy Commissioner of Income Tax, Corporate Circle 1(1), Chennai

In the result the appeal of the Assessee is partly allowed for statistical purposes

ITA 701/CHNY/2025[2020-21]Status: DisposedITAT Chennai01 Dec 2025AY 2020-21

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. Siddhesh Chaugula, C.AFor Respondent: Shri. A R V Sreenivasan, C.I.T
Section 92C

have heard the arguments of the rival parties and perused the material on record. For the reasons adduced in the petition for admission of additional evidence we are convinced that the Assessee did not have sufficient time to furnish the same before the lower authorities and therefore we admit

M/S Parasnath Fuels (P) Ltd., Dehradun vs. DCIT, Dehradun

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

ITA 213/DDN/2024[2017-18]Status: DisposedITAT Dehradun28 Nov 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalparasnath Fuels Pvt. Ltd., The Dcit, Circle 1(1), 28 Feet Road, Dehradun Vikas Nagar, Vs Dehradun - 248198 Pan-Aaicp2190D Assessee Revenue Assessee By Dr. Rakesh Gupta, Adv., Shri Somil Agarwal, Adv. Revenue By Sh. Amar Pal Singh, Jcit Sr. Dr Date Of Hearing 11.09.2025 Date Of Pronouncement 28.11.2025 Order Per Manish Agarwal, Am, This Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appellate Centre [Cit(A), In Short], Dated 08.10.2024 In Appeal No. Nfac/2016-17/10104734 Arising Out Of The Order Passed U/S 147 Of The Income Tax Act, 1961 (‘The Act’) Dt. 08.10.2024 For Assessment Year 2017-18. 2. The Assessee Has Raised Following Grounds Of Appeal: 1. That Having Regard To The Facts & Circumstances Of The Case, Assumption Of Jurisdiction In Initiating The Proceedings U/S 147 & Passing The Impugned Order U/S 147/144B & That Too Without Complying With Mandatory Conditions U/S 147 To 151A Parasnath Fuels Pvt.Ltd. Vs. Dcit

Section 115BSection 147Section 234ASection 68

order without providing sufficient opportunity to the assessee. Before us,vide letter dt. 08.09.2025, the ld. AR filed a prayer for the admission of additional evidence under Rule 29 of the Income Tax Appellate Tribunal Rules, wherein following documents are requested to be admitted as additional evidences: i. Copy ... deletion of the additions made. 6. In reply, ld. Sr DR vehemently supported the orders of lower authorities and opposed the admission of additional evidences filed before us and submits that despite of ample opportunities provided, assessee has not filed any details before the lower authorities. He thus requested

Eics Consultancy Pvt. Ltd., Bilaspur vs. ACIT, Circle-1(1), Bilaspur

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

ITA 504/RPR/2025[2011-12]Status: DisposedITAT Raipur27 Nov 2025AY 2011-12

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.504/Rpr/2025 "नधा"रण वष" / Assessment Year : 2011-12 Eics Consultancy Private Limited B-202, Rama City Centre, Rama Valley, Bodri, Parsada, Bilaspur (C.G.)-495 220 Pan: Aabce8705A ........अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-1(1), Raipur (C.G.)

For Appellant: Shri G.S. Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 250(4)

outset, the Ld. Counsel for the assessee submitted that he has filed an application under Rule 29 of the ITAT Rules, 1963 for admission of additional evidences which the assessee could not furnished before the Revenue authorities. The aforesaid application is extracted as follows: 3 EICS Consultancy Private Limited

Urlife Lifestyle Wellness Limited, Hyderabad vs. Assistant Commissioner of Income-Tax, Corporate Circle 4(1), Chennai

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

ITA 2160/CHNY/2025[AY 2021-22]Status: DisposedITAT Chennai27 Nov 2025

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita No.: 2160/Chny/2025 िनधा"रण वष"/Assessment Year: 2021-22 Urlife Lifestyle Wellness The Assistant Commissioner Ltd., Vs. Of Income Tax, 2Nd Floor, Corporate Circle – 4(1), Apollo Health City, Chennai. Apollo Hospitals Complex, Jubilee Hills, Film Nagar, Hyderabad – 500 096. Pan: Aadca 8021H (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri K. Abhiroop Bhargav, Ca ""यथ" क" ओर से/Respondent By : Ms. T. Mythili, Jcit सुनवाई क" तारीख/Date Of Hearing : 26.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 27.11.2025

For Appellant: Shri K. Abhiroop Bhargav, CAFor Respondent: Ms. T. Mythili, JCIT
Section 11Section 143(3)Section 250Section 37(1)

expenditure cannot be disallowed. The assessee before ITAT has filed petition under Rule 29 of the Income Tax (Appellate Tribunal) Rules, 1963, for admission of additional evidence. The additional evidence that is sought to be admitted is the consultancy contract for services entered by the assessee with the various doctors

Madhvi Ajitkumar Ranka, Na vs. Arivs.ACIT, Navsari Circle, Navsari

In the result, the appeal is allowed for statistical purposes

ITA 124/SRT/2025[2016-17]Status: DisposedITAT Surat26 Nov 2025AY 2016-17

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.124/Srt/2025 Assessment Year: (2017-18) (Hybrid Hearing) Madhvi Ajitkumar Ranka, Vs. Acit, 88, Sunder Nagar, Jamalpore, Navsari Circle, Navsari – 396445 Navsari "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ahfpr5791K (Appellant) (Respondent) Appellant By Shri Darshit J. Naik, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 01/09/2025 Date Of Pronouncement 26/11/2025

Section 250Section 253(3)Section 271(1)(c)Section 40Section 68

condone the delay and admit the appeal for hearing. 6. During the course of hearing, the appellant filed an application dated 03.06.2025, seeking admission of additional evidences for AY 2016-17. These additional evidences include affidavit of tax consultant sworn before a Notary, confirmations and affidavits of persons from whom ... that aforementioned evidences are essential for proper adjudication of the issues in dispute. 7. The ld. Sr. DR for the revenue opposed the admission of additional evidence, stating that sufficient opportunity had been granted during assessment and appellate proceedings. 8. We have considered the contentions of both the parties

DCIT, Circle -3(1), Visakhapatnam vs. Nord Anglia Education Infrastructure Private Limited, Visakhapatnam

In the result, all the appeals filed by the revenue, viz

ITA 314/VIZ/2025[2014-15]Status: DisposedITAT Visakhapatnam26 Nov 2025AY 2014-15

Bench: Shri Ravish Sood & Shri Balakrishnan S.

For Appellant: 1.Shri Karnjot Singh KhuranaFor Respondent: Shri Badicala Yadagiri, CIT-DR
Section 143(3)

calling for remand report from the Assessing Officer on the additional evidence submitted by the assessee by filing application before Ld.CIT(A) for admission of additional evidence viz., copy of lease deed dated 02.02.2017 for leasing 12103 sq. yards of land to M/s. Oakbridge Education Society, copy of security services ... submitted that though the assessee company had filed before the CIT(A) an application for admission of “additional evidence” U/rule 46A of the Income-tax Rules, 1962, but the same was w.r.t seeking admission of a certificate issued by a registered chartered accountant providing a detailed account of utilization

DCIT, Circle - 3(1), Visakhapatnam vs. Nord Anglia Education Infrastructure Private Limited, Visakhapatnam

In the result, all the appeals filed by the revenue, viz

ITA 206/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam26 Nov 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.

For Appellant: 1.Shri Karnjot Singh KhuranaFor Respondent: Shri Badicala Yadagiri, CIT-DR
Section 143(3)

calling for remand report from the Assessing Officer on the additional evidence submitted by the assessee by filing application before Ld.CIT(A) for admission of additional evidence viz., copy of lease deed dated 02.02.2017 for leasing 12103 sq. yards of land to M/s. Oakbridge Education Society, copy of security services ... submitted that though the assessee company had filed before the CIT(A) an application for admission of “additional evidence” U/rule 46A of the Income-tax Rules, 1962, but the same was w.r.t seeking admission of a certificate issued by a registered chartered accountant providing a detailed account of utilization

S N Thakkar Infrastructure Private Limited, Mumbai vs. Circle 14(1)(2), Mumbai

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

ITA 4588/MUM/2025[2018 - 19]Status: DisposedITAT Mumbai26 Nov 2025

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2018-19

For Appellant: Mr. Kirit ShethFor Respondent: 12/11/2025

Income-tax (Appellate Tribunal) Rules, 1963, seeking admission of additional (Appellate Tribunal) Rules, 1963, seeking admission of additional (Appellate Tribunal) Rules, 1963, seeking admission of additional evidence. The additional evidence consists of party-wise details in evidence. The additional evidence consists of party evidence. The additional evidence consists of party

Manish Kantilal Kapadia, Mumbai vs. ACIT CC 8(2), Mumbai

In the result, all the appeals for AY 2014-15 are allowed partly

ITA 322/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Nov 2025AY 2019-20

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: NoneFor Respondent: Mr. Uma Shankar Prasad, CIT-DR
Section 132Section 142(1)Section 143(2)Section 145(3)Section 153ASection 68

ledger extracts eventually filed were tendered only at the eleventh hour, leaving no opportunity for meaningful verification; and significantly, no application seeking admission of additional evidence was preferred before the Ld. CIT(A). 5.2 In the absence of even the rudiments of proof supporting the claim that actual trading