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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

Ultimate Construction, Bhopal vs. DCIT-1(1), Bhopal

Appeal is partly allowed

ITA 379/IND/2023[2010-11]Status: DisposedITAT Indore29 Feb 2024AY 2010-11

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year : 2010-11 Ultimate Construction, Dcit-1(1), G-1, Kamdenu Tower, Bhopal बनाम/ E-2/21, Arera Colony, Vs. Bhopal (Appellant/Assessee) (Respondent/Revenue) Pan: Aabfu9241J Assessee By Shri S.S. Deshpande, C.A. Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 30.01.2024 Date Of Pronouncement 29.02.2024

Section 143(2)Section 143(3)Section 253(5)Section 68

shape of A/c Confirmation of lender, Bank Statement of lender and Assessee’s own bank statement to CIT(A) in terms of Rule 46A of Income-tax Rules, 1962. The CIT(A) admitted those evidences after obtaining remand- report from AO. However, the CIT(A) upheld addition making these observations ... evidences in the shape of Bank Statement of one M/s Unitrade & Services and Assessee’s own Bank Statement to CIT(A) in terms of Rule 46A of Income-tax Rules, 1962. The CIT(A) admitted those evidences after obtaining remand-report from AO. However, on perusal of bank statements

Amit Jain, Delhi vs. ACIT, Central Circle- 6, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 3914/DEL/2019[2013-14]Status: DisposedITAT Delhi29 Feb 2024AY 2013-14

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.3914/Del/2019 िनधा"रणवष"/Assessment Year:2013-14 बनाम Amit Jain, Acit 151, Savita Vihar, Delhi. Vs. Central Circle-6 Pan No.Aafpj5124R Room No.364, E-2, Ara Centre, Jhandewalan, New Delhi. अपीलाथ" Appellant ""यथ"/Respondent

Section 153ASection 68

proved and hence, no addition is warranted u/s 68 of the Act. 4. All the above documents were filed as additional evidence under Rule 46A of the Act before the Ld.CIT(A). The Ld.CIT(A) called for a remand report for the comments of the AO. In the remand report

Budumuru Sandeep Kumar, Vizianagaram vs. Income Tax Officer, Ward-1, Vizianagaram

In the result, appeal of the assessee is allowed

ITA 282/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.282/Viz/2023 (ननधधारण वर्ा / Assessment Year : 2017-18) Budumuru Sandeep Kumar Vs. Income Tax Officer Near Ramabhajana Ward-1 Rangaraya Puram Vizianagaram Bobbili, Vizianagaram [Pan : Bgtpb5972Q] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Dr.Aparna Villuri, DR
Section 115BSection 133(6)Section 143(3)Section 46ASection 69A

affidavits as evidence before the Ld.CIT(A), but the Ld.CIT(A) has not considered the affidavits since the assessee has not filed petition under Rule 46A of Income Tax Rules to admit the additional evidence. He submitted that there is no unexplained investment

Smt. Anjani Kumari Vardha, Vijayawada vs. The ITO, Vijayawada

ITA 207/VIZ/2017[2011-2012]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2011-2012

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble(Through Hybrid Hearing) आयकर अपील सं./ I.T.A. Nos. 215/Viz/2015 & 207/Viz/2017 ("नधा"रण वष" / Assessment Years: 2010-11 & 2011-12) Smt. Anjani Kumari Varada, Vs. Income Tax Officer, Vijayawada. Ward-1(4), Pan: Acvpv 2970 M Vijayawada. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Assessee By : Sri Bvs Chalapathi Rao ""याथ" क" ओर से / Revenue By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Sri BVS Chalapathi RaoFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 131Section 143(1)Section 143(2)Section 143(3)

assessee is not entitled to produce any additional evidence since he is not covered by any of the four clauses laid down in Rule 46A of the Income Tax Rules, 1961. Even then, the Ld. CIT (A) following the principles of natural justice, admitted the additional evidence filed

Anjani Kumari Varada, Vijayawada vs. The ITO, Vijayawada

ITA 215/VIZ/2015[2010-11]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2010-11

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble(Through Hybrid Hearing) आयकर अपील सं./ I.T.A. Nos. 215/Viz/2015 & 207/Viz/2017 ("नधा"रण वष" / Assessment Years: 2010-11 & 2011-12) Smt. Anjani Kumari Varada, Vs. Income Tax Officer, Vijayawada. Ward-1(4), Pan: Acvpv 2970 M Vijayawada. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Assessee By : Sri Bvs Chalapathi Rao ""याथ" क" ओर से / Revenue By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Sri BVS Chalapathi RaoFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 131Section 143(1)Section 143(2)Section 143(3)

assessee is not entitled to produce any additional evidence since he is not covered by any of the four clauses laid down in Rule 46A of the Income Tax Rules, 1961. Even then, the Ld. CIT (A) following the principles of natural justice, admitted the additional evidence filed

Satesh Gopal, Hosur vs. ITO, Hosur

The appeal stand allowed for statistical purposes

ITA 1159/CHNY/2023[2016-17]Status: DisposedITAT Chennai28 Feb 2024AY 2016-17

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manomohan Das

For Appellant: Shri T.S.Lakshmi Venkatraman(FCA)-Ld. ARFor Respondent: Shri P. Sajit Kumar,(JCIT) –Ld. Sr. DR
Section 143(3)Section 144

attention to ground No.2 and submitted that Ld. CIT(A) did not admit additional evidences as filed by the assessee in terms of Rule 46A. The Ld. AR pleaded for another opportunity of hearing before Ld. AO. The Ld. Sr. DR opposed the same and submitted that

Sathesh Gopal, Hosur vs. ITO, Hosur

The appeal stand allowed for statistical purposes

ITA 1158/CHNY/2023[2016-17]Status: DisposedITAT Chennai28 Feb 2024AY 2016-17

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manomohan Das

For Appellant: Shri T.S.Lakshmi Venkatraman(FCA)-Ld. ARFor Respondent: Shri P. Sajit Kumar,(JCIT) –Ld. Sr. DR
Section 143(3)Section 144

attention to ground No.2 and submitted that Ld. CIT(A) did not admit additional evidences as filed by the assessee in terms of Rule 46A. The Ld. AR pleaded for another opportunity of hearing before Ld. AO. The Ld. Sr. DR opposed the same and submitted that

Maharashtra Seamless Ltd., New Delhi vs. DCIT, Circle- 16(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 7065/DEL/2019[2012-13]Status: DisposedITAT Delhi27 Feb 2024AY 2012-13

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Ms. Supriya Mehta, CAFor Respondent: Sh. Manu Chaurasia, Sr. DR

grossly erred both on facts and in law in confirming the action of the AO/TPO rejecting the additional evidences filed by the assessee under rule 46A of the Income Tax Rules, 1962. 6. On the facts and circumstances of the case, the learned CIT(A) has grossly erred both

Basuki Vyapaar Pvt.Ltd., Kolkata vs. ITO, Ward- 8(1), Kolkata

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

ITA 184/KOL/2023[2013-14]Status: DisposedITAT Kolkata23 Feb 2024AY 2013-14

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. No.184/Kol/2023 Assessment Year: 2013-14 Basuki Vyapaar Pvt. Ltd. ………. Appellant (Pan: Aaccb6156B) Vs. Income Tax Officer, Ward-8(1), Kolkata. …………….. Respondent Appearances By: N O N E Appeared For Appellant. Shri Jitendra Kantilal Surti, Jcit (Dr) Appeared For Respondent. Date Of Concluding The Hearing : 05.02.2024 Date Of Pronouncing The Order : 23.02.2024 Order Per Manish Borad: This Appeal Filed By The Assessee Pertaining To The Assessment Year (In Short “Ay”) 2013-14 Is Directed Against The Order Passed U/S 250 Of The Income Tax Act, 1961 In Short The “Act”) By Ld. Commissioner Of Income-Tax, Nfac, Delhi [In Short Ld. “Cit(A)”] Dated 09.01.2023 Arising Out Of The Assessment Order Framed U/S 143(3) Of The Act By Ito, Ward-8(1) Dated 08.03.2016. 2. When The Case Was Called Or None Appeared On Behalf Of The Assessee. In The Past Also When The Case Was Fixed For Hearing On 06.06.2023 & 23.08.2023, There Was No Compliance. We Thus

Section 143(2)Section 143(3)Section 250Section 68

without allowing the appellant any proper opportunity of being heard. 2. For that the appellant craves leave to produce additional evidences in terms of Rule 46A of the Income Tax Rules 1962. 3. For that the order passed by the Ld. CIT (A) is bad in law since ... assessee is that it was not provided sufficient opportunity of being heard and also it could not produce additional evidence in terms of Rule 46A. In a nutshell the prayer of the assessee in the grounds is that the matter may be remitted back to the file

ACIT, CC - I (2), Chennai vs. M/S. Balaji Hotels & Enterprises Ltd., Chennai

In the result, the appeals filed by the Revenue in ITA Nos

ITA 209/CHNY/2020[2010-11]Status: DisposedITAT Chennai23 Feb 2024AY 2010-11

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri V. Nandakumar, CITFor Respondent: Shri D. Anand, Advocate
Section 139Section 139(5)Section 143(3)

business income of Rs.2 crores being advance and deposits written off. Further, the Revenue has raised the issue of violation of Rule 46A of the Income Tax Rules, 1962 (hereinafter the ‘Rules’) and admitted additional evidence without providing opportunity to the AO. For these issues, the Revenue has raised ... following two grounds:- 2. Whether on the facts and in the circumstances of the case and on a proper interpretation of Rule 46A of the Income Tax Rules, 1962, the ld.CIT(A) was right in taking a decision on the merits of an issue which has not been decided

ACIT, CC - I (2), Chennai vs. M/S. Balaji Hotels & Enterprises Ltd., Chennai

In the result, the appeals filed by the Revenue in ITA Nos

ITA 208/CHNY/2020[2009-10]Status: DisposedITAT Chennai23 Feb 2024AY 2009-10

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri V. Nandakumar, CITFor Respondent: Shri D. Anand, Advocate
Section 139Section 139(5)Section 143(3)

business income of Rs.2 crores being advance and deposits written off. Further, the Revenue has raised the issue of violation of Rule 46A of the Income Tax Rules, 1962 (hereinafter the ‘Rules’) and admitted additional evidence without providing opportunity to the AO. For these issues, the Revenue has raised ... following two grounds:- 2. Whether on the facts and in the circumstances of the case and on a proper interpretation of Rule 46A of the Income Tax Rules, 1962, the ld.CIT(A) was right in taking a decision on the merits of an issue which has not been decided

ACIT, CC - I (2), Chennai vs. M/S. Balaji Hotels & Enterprises Ltd., Chennai

In the result, the appeals filed by the Revenue in ITA Nos

ITA 207/CHNY/2020[2008-09]Status: DisposedITAT Chennai23 Feb 2024AY 2008-09

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri V. Nandakumar, CITFor Respondent: Shri D. Anand, Advocate
Section 139Section 139(5)Section 143(3)

business income of Rs.2 crores being advance and deposits written off. Further, the Revenue has raised the issue of violation of Rule 46A of the Income Tax Rules, 1962 (hereinafter the ‘Rules’) and admitted additional evidence without providing opportunity to the AO. For these issues, the Revenue has raised ... following two grounds:- 2. Whether on the facts and in the circumstances of the case and on a proper interpretation of Rule 46A of the Income Tax Rules, 1962, the ld.CIT(A) was right in taking a decision on the merits of an issue which has not been decided

Akhilesh Shukla, Bhopal vs. The ITO 1(1), Bhopal

Appeal is allowed

ITA 160/IND/2023[2011-12]Status: DisposedITAT Indore22 Feb 2024AY 2011-12

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year:2011-12 Shri Akhilesh Shukla, Income-Tax Officer, 18/2, Rizwan Bagh, 1(1), बनाम/ Vip Road, Bhopal Vs. Bhopal (Assessee/Appellant) (Revenue/Respondent) Pan: Afops5580E Assessee By Shri Ashish Goyal, Ca & Shri N.D. Patwa, Adv. Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 16.01.2024 Date Of Pronouncement 22.02.2024

Section 143(2)Section 143(3)Section 44ASection 69

appeal, the assessee was having exact details supported by documents and therefore submitted those documents as additional evidences to CIT(A) in terms of Rule 46A of Income- tax Rules, 1962 whereupon the CIT(A) called a remand-report from AO. But the AO did not file any remand-report ... Shri Akhilesh Shukla, Bhopal vs. ITO, 1(1), Bhopal. ITA No.160/Ind/2023 – AY 2011-12 admitted by CIT(A) in terms of Rule 46A of Income-tax Rules, 1962 and the department has not challenged the action of CIT(A) by way of any cross- objection. Considering these aspects, we find

Bhailalbhai Mafatlal Pujara, Mehsana vs. The Income Tax Officer, Ward-5, Mehsana

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

ITA 885/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad21 Feb 2024AY 2017-18

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita No.885/Ahd/2023 धििाधरणवरध/Asstt. Year: 2017-2018 Bhailalbhai Mafatlal Pujara, Income Tax Officer, 100 Sivam Gate, Vs. Ward-5, Dayanand Complex, Mehsana. Becharaji, Mehsana-384210. Pan: Aetpp7146K

For Appellant: Shri Suchit Patel, ARFor Respondent: Shri V.K Mangla, Sr. DR
Section 44ASection 69A

matter before the Ld. CIT(A). The assessee before the Ld. CIT(A), filed the additional documents with the prayer for admission under rule 46A of Income Tax Rules. The Ld. CIT(A) also called for the remand report from the AO who opposed to admit the additional evidence ... evidence on the merit of the case. However, Ld. CIT(A), rejected the application of the assessee for the admission of additional evidence under rule 46A of income tax rules by observing as under: A.Y. 2017-18 3 8. Decision:I have carefully considered the facts of the case, submissions

Shri. B.S.Ramachandra, Periyapatna vs. Assistant Commissioner of Income-Tax, Circle-1(1) & Tps, Mysore

In the result, appeal filed by the Assessee stands allowed for

ITA 897/BANG/2023[2017-18]Status: DisposedITAT Bangalore21 Feb 2024AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year: 2017-18

For Appellant: Ms. Sunaiana Bhatia, Ld. CAFor Respondent: Shri Subramanian. S, Ld. JCIT
Section 115BSection 144Section 250Section 69A

prove the genuineness of the claim. In such a situation, the additional evidence :: 3 :: submitted at the stage of appeal cannot be entertained u/s rule 46A . 3.1 The Ld. Commissioner also confirmed the addition of Rs.28,20,000/- as made by the AO u/s.69A r.w.s.115BBE

Niamathulla, Bangalore vs. Income Tax Officer, Ward-3(1)(1), Koramangala

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

ITA 1127/BANG/2023[2017-18]Status: DisposedITAT Bangalore21 Feb 2024AY 2017-18

Bench: Shri George George K. & Shri Chandra Poojariassessment Year: 2017-18 Niamathulla No.43/1, 1St Floor, Mtb Road Near Popular Auto Mobile Ito Vs. Kalasipalyam 560 002 Koramangala Karnataka Bangalore Pan No.Ahepn8663K Assessee Respondent Assessee By : Smt. Sheetal, A.R. Revenue By : Dr. Nischal, D.R. Date Of Hearing : 21.02.2024 Date Of Pronouncement : 21.02.2024 O R D E R Per Chandra Poojari: This Appeal By Assessee Is Directed Against The Order Of Nfac For The Assessment Year 2017-18 Dated 17.11.2023. The Assessee Has Raised Following Grounds Of Appeal:

For Appellant: Smt. Sheetal, A.RFor Respondent: Dr. Nischal, D.R
Section 144Section 147Section 148Section 250

vouchers are all self-made and transactions are in cash. These evidences could also not be admitted since no request for the admission under Rule 46A Niamathulla, Kalasipalyam Page 3 of 4 was made. The large transactions above Rs.50,000/- have also not been explained. The assessee is a trader ... before NFAC, the documents filed by the assessee are unverifiable and also there was no application by assessee to admit those evidences under Rule 46A of I.T. Rules. Thus he submitted that the issue may be remitted back to the file of ld. AO for fresh consideration. Niamathulla, Kalasipalyam Page

Casa Grande Civil Engineering Private Limited, Chennai vs. ACIT National E-Assessment Centre, Delhi

The appeal of the assessee stand partly allowed for statistical purposes

ITA 64/CHNY/2023[2018-19]Status: DisposedITAT Chennai20 Feb 2024AY 2018-19

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं./ Ita No.64/Chny/2023 (िनधा"रण वष" / Assessment Year: 2018-19) M/S. Casa Grande Civil Jcit (Osd) Engineering Private Limited Corporate Circle-1(1) बनाम/ Vs. 5Th Floor, Npl Devi, Lb Road, Chenai-34. Thiruvanmiyur, Chennai-600 041. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-5227-K (अपीलाथ"/Appellant) : (!"थ" / Respondent) & 2. आयकरअपील सं./ Ita No.189/Chny/2023 (िनधा"रण वष" / Assessment Year: 2018-19) Jcit (Osd) M/S. Casa Grande Civil Engineering बनाम Corporate Circle-1(1) Private Limited, 5Th Floor, Npl Devi, Lb Road, Chenai-34. / Vs. Thiruvanmiyur, Chennai-600 041. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-5227-K (अपीलाथ"/Appellant) : (!"थ" / Respondent) & 3. Cross Objection No.49/Chny/2023 (In Ita No.189/Chny/2023) (िनधा"रण वष" / Assessment Year: 2018-19) बनाम/ M/S. Casa Grande Civil Engineering Jcit (Osd) Private Limited, Corporate Circle-1(1) Vs. 5Th Floor, Npl Devi, Lb Road, Chenai-34. Thiruvanmiyur, Chennai-600 041. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-5227-K (अपीलाथ"/Cross Objector) : (!"थ" / Respondent) अपीलाथ"कीओरसे/ Assessee By : Shri G. Reddi Prakash (Ca)- Ld. Ar !"थ"कीओरसे/ Revenue By : Shri P. Sajit Kumar(Jcit)-Ld. Sr. Dr

For Appellant: Shri G. Reddi Prakash (CA)- Ld. ARFor Respondent: Shri P. Sajit Kumar(JCIT)-Ld. Sr. DR
Section 143(3)

refused to admit additional evidences as filed by the assessee during appellate proceedings since the same were not filed as per Rule 46A of Income Tax Rules. Aggrieved, the assessee is in further appeal before us. 8.2 The Ld. AR has submitted that the assessee is in a position

JCIT(OSD), Corporate Circle-1(1), Chennai vs. M/S Casa Grande Civil Engineering Pvt. Ltd., Chennai

The appeal of the assessee stand partly allowed for statistical purposes

ITA 189/CHNY/2023[2018-19]Status: DisposedITAT Chennai20 Feb 2024AY 2018-19

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं./ Ita No.64/Chny/2023 (िनधा"रण वष" / Assessment Year: 2018-19) M/S. Casa Grande Civil Jcit (Osd) Engineering Private Limited Corporate Circle-1(1) बनाम/ Vs. 5Th Floor, Npl Devi, Lb Road, Chenai-34. Thiruvanmiyur, Chennai-600 041. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-5227-K (अपीलाथ"/Appellant) : (!"थ" / Respondent) & 2. आयकरअपील सं./ Ita No.189/Chny/2023 (िनधा"रण वष" / Assessment Year: 2018-19) Jcit (Osd) M/S. Casa Grande Civil Engineering बनाम Corporate Circle-1(1) Private Limited, 5Th Floor, Npl Devi, Lb Road, Chenai-34. / Vs. Thiruvanmiyur, Chennai-600 041. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-5227-K (अपीलाथ"/Appellant) : (!"थ" / Respondent) & 3. Cross Objection No.49/Chny/2023 (In Ita No.189/Chny/2023) (िनधा"रण वष" / Assessment Year: 2018-19) बनाम/ M/S. Casa Grande Civil Engineering Jcit (Osd) Private Limited, Corporate Circle-1(1) Vs. 5Th Floor, Npl Devi, Lb Road, Chenai-34. Thiruvanmiyur, Chennai-600 041. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-5227-K (अपीलाथ"/Cross Objector) : (!"थ" / Respondent) अपीलाथ"कीओरसे/ Assessee By : Shri G. Reddi Prakash (Ca)- Ld. Ar !"थ"कीओरसे/ Revenue By : Shri P. Sajit Kumar(Jcit)-Ld. Sr. Dr

For Appellant: Shri G. Reddi Prakash (CA)- Ld. ARFor Respondent: Shri P. Sajit Kumar(JCIT)-Ld. Sr. DR
Section 143(3)

refused to admit additional evidences as filed by the assessee during appellate proceedings since the same were not filed as per Rule 46A of Income Tax Rules. Aggrieved, the assessee is in further appeal before us. 8.2 The Ld. AR has submitted that the assessee is in a position

Prime Maxi Promotion Service Pvt. Ltd., New Delhi vs. ACIT Circle-20(1), New Delhi

ITA 3453/DEL/2019[2014-15]Status: DisposedITAT Delhi20 Feb 2024AY 2014-15

Bench: Shri M. Balaganesh & Ms Astha Chandram/S. Prime Maxi Vs. Acit, Promotion Pvt. Ltd, Circle-20(1), 115, Ansal Bhawan, 16, New Delhi Kg Marg, New Delhi (Appellant) (Respondent) Pan: Aaacp6716D Assessee By : Shri R. S. Singhvi, Ca Shri Satayjit Goel, Ca Revenue By: Ms. Harpreet Kaur, Sr. Dr Date Of Hearing 22/11/2023 Date Of Pronouncement 20/02/2024

For Appellant: Shri R. S. Singhvi, CAFor Respondent: Ms. Harpreet Kaur, Sr. DR
Section 143(3)

assessment was ITA No. 3453/Del/201 Prime Maxi Promotion Pvt. Ltd made on 2.12.2016 ie. within a week of seeking details. Therefore, prerequisite of Rule 46A of IT Rules, 1962 were met. 1.2 That on the facts and circumstances of the case and in law, the CIT(A) did not appreciate

Dhadda Gem N Jewels, Mumbai vs. ITO Ward19(1)(4), 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 662/MUM/2023[2012-13]Status: DisposedITAT Mumbai19 Feb 2024AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2012-13

For Appellant: Shri Vimal Punmiya, A.RFor Respondent: Smt. Mahita Nair, Sr. DR
Section 133(6)Section 148

nature of additional evidence the nature of additional evidences, then the assessee may file then the assessee may file application under rule 46A of the Income Tax Rules, 1962 and application under rule 46A of the Income Tax Rules, 1962 and application under rule 46A of the Income Tax Rules