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“rule 46A”

AppealsRule 46ARule 46A2,967 judgments

The decision most relied on for rule 46A is CIT v. Divine Leasing & Finance Ltd. (299 ITR 268), cited in 426 judgments on BharatTax.

Leading authorities on rule 46A

CIT v. Divine Leasing & Finance Ltd.
299 ITR 268 · 2008 · High Court
426
citing judgments

The Assessing Officer cannot add share capital or share premium amounts if the assessee provides the identity and creditworthiness of the subscriber and establishes the genuineness of the transaction. The court may admit additional evidence under Rule 46A, such as the PAN identity of the creditor.

CIT v. Jansampark Advertising & Marketing (P.) Ltd.
56 Taxmann.com 286 · 2015 · High Court
196
citing judgments

The Commissioner of Income-tax (Appeals) has an independent statutory obligation to conduct proper inquiries and verify facts, especially when the Assessing Officer has failed to do so. The CIT(A) must ensure effective inquiry is carried out before deleting additions or accepting additional 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. Nikunj Eximp
216 Taxmann.com 171 · 2013 · High Court
103
citing judgments

The Assessing Officer must consider additional evidence produced before the CIT(A) under Rule 46A and cannot reject it without proper appreciation of the facts, especially when the assessee was prevented by sufficient cause from producing it earlier.

CIT v. Virgin Securities & Credits (P) Ltd.
332 ITR 396 · 2011 · High Court
85
citing judgments

The Commissioner of Income-tax (Appeals) must admit additional evidence if it is crucial for the proper disposal of the appeal, ensuring substantial justice to the appellant.

CIT v. Manish Buildwell (P) Ltd.
245 CTR 397 · 2011 · High Court
58
citing judgments

The production of fresh evidence at the appellate stage before the Commissioner (Appeals) is strictly governed by the conditions and procedures laid down in Rule 46A of the Income-tax Rules.

CIT v. Ranjit Kumar Choudhury
288 ITR 179 · 2007 · High Court
55
citing judgments

The appellate authority must follow Rule 46A of the Income Tax Rules when admitting additional evidence, which includes recording reasons for admission and providing the Assessing Officer an opportunity to verify or refute the evidence. Failure to do so violates principles of natural justice.

Judgments citing rule 46A

Ranar Agrochem Limited, Parawada vs. Deputy Commissioner of Income Tax, Visakhapatnam

ITA 288/VIZ/2024[2014-15]Status: DisposedITAT Visakhapatnam31 Aug 2026AY 2014-15

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.288/Viz/2024 (िनधा"रण वष"/Assessment Year:2014-15) Ranar Agrochem Limited, Vs. Deputy Commissioner Visakhapatnam. Of Income Tax, Visakhapatnam. Pan: Aaccp0372M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M. Madhusudan, Ca (Hybrid) राज" व "ारा/Revenue By: Sri Jenardhanan V, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 14/10/2025 घोषणा की तारीख/Date Of 31/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Center (Nfac), Delhi, Dated 15/05/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “A.O.”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short “The Act”) Dated 30/12/2016 For A.Y.

For Appellant: Shri M. Madhusudan, CAFor Respondent: Sri Jenardhanan V, CIT-DR
Section 143(2)Section 143(3)Section 250Section 36(1)Section 36(1)(va)Section 40Section 68

आयकर अपीलीय अिधकरण, िवशाखापटणम पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Visakhapatnam Bench, Visakhapatnam Before Shri Manjunatha G., Accountant Member

Shyam Sunder, Gururgam vs. ITO ( Circle 4(1), Gurgram

In the result, the appeal of the assessee is dismissed

ITA 4779/DEL/2024[2011-12]Status: DisposedITAT Delhi31 Aug 2026AY 2011-12

Bench: SHRI ANUBHAV SHARMA (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: NoneFor Respondent: Shri Manish Gupta, Sr. DR
Section 143(2)Section 147Section 148Section 2Section 2(14)Section 54BSection 54F

proceedings. It was further noted that, even at the appellate stage, the assessee failed to file any cogent documentary evidence or a petition under Rule 46A to controvert the findings of the Assessing Officer. 5.2 The CIT(A) held that the assessee did not substantiate the claim that the land ... properties, and the same has been duly confirmed by the Ld. CIT(A). The assessee also failed to file any additional evidence or Rule 46A application before the first appellate authority. 9.4 In view of the above facts and circumstances, we find no infirmity in the order passed

Anil Arjun Waghmare, Mumbai vs. I.T.O, Ward 32(1)(1), Mumbai

In the result, appeal filed by the assessee is dismissed

ITA 1611/MUM/2025[2017-18]Status: DisposedITAT Mumbai29 Jul 2026AY 2017-18

Bench: Shri Sandeep Gosain(Jm) & Shri Prabhash Shankar(Am) Anil Arjun Waghmare Ito Ward 32(1)(1) A 203, Alka Bhavan Room No. 703 Eksar Road, Sainath Vs. Kautilya Bhavan Nagar, Borivali West C-41 To C-43 Mumbai-400 103. Bandra, Mumbai-51. Pan : Aajpw1608B Appellant Respondent

For Appellant: Shri Aditya RaiFor Respondent: None
Section 250

ground that the same has been filed without any accompanying petition making out of case under any of the four limbs of Rule 46A(1) of the Income Tax Rules, 1962. 5. After hearing Ld. DR and after evaluating records, we are of the view that since assessee

Income Tax Officer (TDS-3), Ahmedabad vs. Tarun Santramdas Varma, Ahmedabad

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

ITA 2549/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kmble

For Appellant: Shri Abhijit, Sr.DRFor Respondent: Shri Tushar Hemani, Sr. Advocate
Section 143(3)Section 194Section 201Section 250Section 46A

Aggrieved by the order of the Ld. CIT(A), the Revenue is now in appeal before us. Ground No. 1: Violation of Rule 46A 6. The Revenue has contended that the Ld. CIT(A) erred in admitting additional evidences without providing an opportunity to the Assessing Officer, thereby violating Rule

Alaina Bullions Private Limited, New Delhi vs. DCIT Central Circle, Ghaziabad

In the result, appeals of the Revenue in ITA No

ITA 916/DEL/2023[2017-18]Status: DisposedITAT Delhi20 Mar 2026AY 2017-18

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2017-18] M/S Alaina Buillions Private Assistant Commissioner Of Limited, Income Tax, Central Circle, 1St Floor, Panna Bhawan, Nel Ghaziabad, Room No.229, 2Nd Vs Gali, Sarafa Bazar, Meerut, Floor, Cgo-1, Hapur Chungi, Uttar Pradesh-250002 Ghaziabad, Uttar Pradesh-201002 Pan-Aanca8659D Appellant Respondent

Section 153A

circumstances, the additional evidences should not have been admitted as the case of the assessee is not fulfilling the categorical conditions laid down in Rule 46A. 3. On facts and circumstances of the case and in law, the Ld. CIT(A) erred in reaching conclusion that the action ... case and in law, the Ld. CIT (A) erred in admitting the additional evidences without appreciating the fact that the conditions of Rule 46A(1) of Income Tax Rules, 1962 under which additional evidences could be filed before the Ld. CIT(A) was not satisfied, as the CIT(A) admitted

ACIT, Central Circle, Ghaziabad vs. Alaina Bullions Private Limited, Meerut

In the result, appeals of the Revenue in ITA No

ITA 1461/DEL/2023[2017-18]Status: DisposedITAT Delhi20 Mar 2026AY 2017-18

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2017-18] M/S Alaina Buillions Private Assistant Commissioner Of Limited, Income Tax, Central Circle, 1St Floor, Panna Bhawan, Nel Ghaziabad, Room No.229, 2Nd Vs Gali, Sarafa Bazar, Meerut, Floor, Cgo-1, Hapur Chungi, Uttar Pradesh-250002 Ghaziabad, Uttar Pradesh-201002 Pan-Aanca8659D Appellant Respondent

Section 153A

circumstances, the additional evidences should not have been admitted as the case of the assessee is not fulfilling the categorical conditions laid down in Rule 46A. 3. On facts and circumstances of the case and in law, the Ld. CIT(A) erred in reaching conclusion that the action ... case and in law, the Ld. CIT (A) erred in admitting the additional evidences without appreciating the fact that the conditions of Rule 46A(1) of Income Tax Rules, 1962 under which additional evidences could be filed before the Ld. CIT(A) was not satisfied, as the CIT(A) admitted

ACIT, Central Circle, Ghaziabad vs. Alaina Bullions Private Limited, Meerut

In the result, appeals of the Revenue in ITA No

ITA 1460/DEL/2023[2016-17]Status: DisposedITAT Delhi20 Mar 2026AY 2016-17

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2017-18] M/S Alaina Buillions Private Assistant Commissioner Of Limited, Income Tax, Central Circle, 1St Floor, Panna Bhawan, Nel Ghaziabad, Room No.229, 2Nd Vs Gali, Sarafa Bazar, Meerut, Floor, Cgo-1, Hapur Chungi, Uttar Pradesh-250002 Ghaziabad, Uttar Pradesh-201002 Pan-Aanca8659D Appellant Respondent

Section 153A

circumstances, the additional evidences should not have been admitted as the case of the assessee is not fulfilling the categorical conditions laid down in Rule 46A. 3. On facts and circumstances of the case and in law, the Ld. CIT(A) erred in reaching conclusion that the action ... case and in law, the Ld. CIT (A) erred in admitting the additional evidences without appreciating the fact that the conditions of Rule 46A(1) of Income Tax Rules, 1962 under which additional evidences could be filed before the Ld. CIT(A) was not satisfied, as the CIT(A) admitted

Harbhol Singh, Sunam vs. Income Tax Officer, Ward Sunam

In the result, the appeal is allowed for statistical purposes

ITA 788/CHANDI/2025[2012-2013]Status: DisposedITAT Chandigarh19 Mar 2026AY 2012-2013

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Krinwant Sahay, Am आयकरअपीलसं./ Ita No.788/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2012-13) Harbhol Singh Ito H. No. 863, Village – Sheron, Aayakar Bhawan, Income Tax बनाम/ Vs. Suman Road, Sunam Officer, Ward Sunam, Sangrur District : Sangrur Punjab - 148028 Punjab - 148028 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Cssps-9948-F (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Deepinder Singh (Advocate) ""थ"कीओरसे/Respondent By : Sh. Vivek Vardhan (Addl. Cit) Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 26-02-2026 घोषणाकीतारीख /Date Of Pronouncement 19-03-2026 : आदेश / O R D E R Krinwant Sahay () This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A)/ Nfac, Delhi Dt. 16/05/2025 For The Assessment Year 2012-13. In The Present Appeal Assessee Raised The Following Grounds:

For Appellant: Sh. Deepinder Singh (Advocate)For Respondent: Sh. Vivek Vardhan (Addl. CIT) Ld. Sr. DR
Section 148

index had been applied, which are not acceptable and as such the addition upheld is illegal, arbitrary and unjustified. 5. That the application under Rule 46A of the Income Tax Rules, 1962, regarding production of additional evidence may please be entertained. 6. That the notice of Demand may kindly ... practiced in rural transactions, and that the registry itself mentions the receipt of funds. The AR pleaded for the admission of additional evidence under Rule 46A to prove the agricultural nature of the land and the source of the cash. 8. Per contra, the Ld. DR, strongly supported the orders

Basant Kumar Mishra, Korba vs. DCIT, Circle-1(1), Bilaspur

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

ITA 72/RPR/2026[2018-19]Status: HeardITAT Raipur19 Mar 2026AY 2018-19

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.71 & 72/Rpr/2026 "नधा"रण वष" /Assessment Year : 2018-19 Basant Kumar Mishra Mig-1-57, Svbp Nagar, Jamnipali, Korba (C.G.)-495 450 Pan: Aktpm2030M

For Appellant: Shri Yash Dhariwal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 250(4)

that the Ld. CIT(Appeals)/NFAC vide Para 6.5.1 had not accepted the additional evidences observing as follows: “6.5.1 Admissibility of Additional Evidence under Rule 46A: Rule 46A of the Income-tax Rules restricts an appellant from adducing additional evidence unless certain conditions are met (e.g., prevention by sufficient cause ... liability discovered by the AO. Therefore, the request to admit the fresh claim of expenses of Rs.21,49,846/- as additional evidence under Rule 46A is hereby rejected.” 3. That at the time of hearing, the Ld. Counsel for the assessee submitted that it is very crucial for the quasi

Basant Kumar Mishara, Korba vs. DCIT, Circle-1(1), Bilaspur, Bilapsur

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

ITA 71/RPR/2026[2018-19]Status: HeardITAT Raipur19 Mar 2026AY 2018-19

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.71 & 72/Rpr/2026 "नधा"रण वष" /Assessment Year : 2018-19 Basant Kumar Mishra Mig-1-57, Svbp Nagar, Jamnipali, Korba (C.G.)-495 450 Pan: Aktpm2030M

For Appellant: Shri Yash Dhariwal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 250(4)

that the Ld. CIT(Appeals)/NFAC vide Para 6.5.1 had not accepted the additional evidences observing as follows: “6.5.1 Admissibility of Additional Evidence under Rule 46A: Rule 46A of the Income-tax Rules restricts an appellant from adducing additional evidence unless certain conditions are met (e.g., prevention by sufficient cause ... liability discovered by the AO. Therefore, the request to admit the fresh claim of expenses of Rs.21,49,846/- as additional evidence under Rule 46A is hereby rejected.” 3. That at the time of hearing, the Ld. Counsel for the assessee submitted that it is very crucial for the quasi

Step Logistics Private Limited, Raipur vs. Dy. Commissioner of Income Tax, Circle 1(1), Raipur

In the result, appeal of the assessee in ITA

ITA 636/RPR/2025[2017-18]Status: DisposedITAT Raipur19 Mar 2026AY 2017-18

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. / Ita No.636/Rpr/2025 "नधा"रण वष" / Assessment Year : 2017-18 Step Logistics Private Limited A-1, Mahavir Gaushala Complex, K.K Road, Raipur (C.G.)-492 001 Pan: Aancs0382F

For Appellant: S/shri Praveen Khandelwal &For Respondent: Dr. Priyanka Patel, Sr. DR
Section 127Section 143(2)Section 143(3)Section 68

Rules, 1963 is hereby admitted and the same is restored to the file of the Ld. CIT(Appeals)/NFAC for compliance in terms with Rule 46A(3) of the IT Rules, 1962 calling for a remand report from the A.O on this issue and decide the same in denovo

H K Ispat Pvt. Ltd., Panchmahal vs. The Dy.CIT, Central Circle-2, Vadodara

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

ITA 1392/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad18 Mar 2026AY 2021-22

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

Section 250Section 68

account of unsecured loan without remanding the matter to the Assessing Officer which in clear violation of the Rule 46A of the Income Tax Rules. 5. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in allowing the contention ... account of unexplained expenditure without remanding the matter to the Assessing Officer which in clear violation of the Rule 46A of the Income Tax Rules. 6. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition

ACIT, Central Circle-2, Vadodara vs. Hk Ispat Pvt Ltd, Godhra

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

ITA 1278/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad18 Mar 2026AY 2021-22

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

Section 250Section 68

account of unsecured loan without remanding the matter to the Assessing Officer which in clear violation of the Rule 46A of the Income Tax Rules. 5. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in allowing the contention ... account of unexplained expenditure without remanding the matter to the Assessing Officer which in clear violation of the Rule 46A of the Income Tax Rules. 6. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition

ACIT, Central Circle-2, Vadodara vs. Hk Ispat Pvt Ltd, Godhra

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

ITA 1277/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad18 Mar 2026AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

Section 250Section 68

account of unsecured loan without remanding the matter to the Assessing Officer which in clear violation of the Rule 46A of the Income Tax Rules. 5. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in allowing the contention ... account of unexplained expenditure without remanding the matter to the Assessing Officer which in clear violation of the Rule 46A of the Income Tax Rules. 6. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition

Suraj Vijay Kulkarni, Mumbai vs. ITO 8(1)(3), Mumbai

In the result, the addition is restricted to Rs

ITA 8317/MUM/2025[2010-11]Status: DisposedITAT Mumbai18 Mar 2026AY 2010-11

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI JAGADISH (Accountant Member)

For Appellant: Shri Vimal Punmiya & Mr. Dhaval SalotFor Respondent: Shri S. Anbuselvan (SR AR)
Section 143(3)Section 148Section 250Section 69

before the AO no such bills/invoices were available, producing copies of self-made vouchers during the course of appeal proceedings, cannot be admitted under rule 46A of IT Rules. Appellant did not prove that he was prevented by sufficient cause from producing the evidence which he was called upon ... expenses towards shifting charges, allegedly paid to various persons, claimed to be occupants of a property is not admitted as evidence under rule 46A of the IT Rules.” Being aggrieved assessee filed an appeal before us. 3. The Learned Authorised Representative (Ld. AR) submitted that a paper book comprising pages

Income Tax Officer Ward-3(1), Raipur vs. Rekha Kukreja, Raipur

In the result, appeal of the Revenue in ITA No

ITA 647/RPR/2025[2014-15]Status: DisposedITAT Raipur17 Mar 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. / Ita Nos.647/Rpr/2025 Co No.25/Rpr/2025 "नधा"रण वष" / Assessment Year : 2014-15 The Income Tax Officer, Ward-3(1), Raipur (C.G.)

For Appellant: Shri R.B Doshi, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

call for a remand report from the A.O along with the attachments specifying the additional evidences filed by the assessee in terms with Rule 46A(3) of Income Tax Rules, 1962 and the A.O shall furnish such ground report after verifying those additional evidences and thereafter, upon submission of such ... order accordingly. 4. That even without going into the merits of the matter, on the issue of additional evidences itself in terms with Rule 46A(3) of Income Tax Rules, 1962, the matter is restored to the file of the Ld. CIT(Appeals)/NFAC as per afore-stated directions

ITO, Ward-1(1)(3), Dehradun vs. Trishla Steel Pvt Ltd, Dehradun

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

ITA 188/DDN/2025[2017-18]Status: DisposedITAT Dehradun13 Mar 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 143(2)Section 68

with the above order, the assessee preferred an appeal before the NFAC, Delhi and assessee filed detailed submissions and also filed additional evidences under Rule 46A. After considering the detailed submission, Id. CIT(A) allowed the grounds raised by the assessee with regard to cash deposits during demonetization period ... issued by MDDA, the google map measurement from the IMA Chungi etc. In addition to this, the appellant relied upon the application furnished under rule 46A, the reply of the TehsildarVikas Nagar , Dehradun dated 10.2.2020made part of submissions stating that that the aerial distance from the municipality limit

Prakashbhai Khengarbhai Dodiya, Surendranagar vs. The ITO Ward 1 Surendranagar, Surendranagar

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

ITA 790/RJT/2025[2018-19]Status: DisposedITAT Rajkot13 Mar 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपीलसं./Ita No. 790/Rjt/2025

For Appellant: Shri Samir Vora, Ld. ARFor Respondent: Shri Dheeraj Kumar Gupta, Ld. Sr. DR
Section 144Section 250

respond to the notices of hearing during the course of assessment. [ it was CORONA Period) and therefore urged to admit additional evidence/explanation as per Rule 46A which the CIT(A) has completely ignored. Hence the appellant should be allowed to produce additional evidence/explanation which should be admitted as additional evidence

Kedony M Ritse, Kohima, Nagaland vs. ITO Ward 1, Dimapur

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

ITA 22/GTY/2026[2020-21]Status: DisposedITAT Guwahati13 Mar 2026AY 2020-21

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

For Appellant: Shri Sidhant Sharma, FCAFor Respondent: Shri Dipak Singh, CIT-DR

passed the order without admitting the additional evidences filed by the assessee on the ground that the application under Rule 46A of the Income Tax Rules, 1962 was not filed. Consequently, in the interest of justice and fair play, we admit the additional evidences filed by the assessee and restore

Kedony M Ritse, Kohima vs. Income Tax Officer Ward-1, Dimapur

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

ITA 436/GTY/2025[2022-23]Status: DisposedITAT Guwahati13 Mar 2026AY 2022-23

Bench: Shriduvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Income Tax Officer, Kedony M Ritse Ward-1, Dimapur H No. 327, Agri Colony, Nr Income Tax Office, Kalibai Road, Stella Hss, Kohima-797001, Vs. Dimapur, Dimapur-797112, Nagaland Nagaland (Appellant) (Respondent) Pan No. Bznpr6041R Assessee By : Shri Sidhant Sharma, Ar Revenue By : Shri Dipak Singh, Dr Date Of Hearing: 10.03.2026 Date Of Pronouncement: 13.03.2026

For Appellant: Shri Sidhant Sharma, ARFor Respondent: Shri Dipak Singh, DR

available on record, we find that the ld. CIT (A) has decided the issue without admitting the additional evidences filed by the assessee under Rule 46A of the Income Tax Rules, 1962, which comprised of Tribal and Caste Certificate, Permanent Resident Certificate, Trade License, GST registration, Work order sheet