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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

ACIT, Circl-43(1), New Delhi vs. Ujala Credit Co- Operative Society Ltd., New Delhi

In the result, appeal of the Revenue is dismissed

ITA 9259/DEL/2019[2015-16]Status: DisposedITAT Delhi19 Jul 2023AY 2015-16

Bench: Shri Kul Bharat & Shri M. Balaganesh

For Appellant: Shri Naveen Agarwal, CA & Ms. Rema Mohan, AdvFor Respondent: Shri Gurpreet Singh, Sr. DR
Section 144

IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH: ‘H’: NEW DELHI) BEFORE SHRI KUL BHARAT JUDICIAL MEMBER & SHRI M. BALAGANESH

Birla Transasia Carpets, Bulandshahr vs. DCIT, New Delhi

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

ITA 4911/DEL/2016[2008-09]Status: DisposedITAT Delhi19 Jul 2023AY 2008-09
Section 143(3)Section 68

creditworthiness of the lenders were not proved by the assessee. Before the Ld. CIT(A), the assessee filed additional evidences in terms of Rule 46A of the Income Tax Rules containing the confirmation of accounts from the lenders, their ITR and annual reports. These additional evidences were duly forwarded

DCIT, New Delhi vs. M/S. Birla Transasia Carpet Ltd., New Delhi

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

ITA 4329/DEL/2016[2008-09]Status: DisposedITAT Delhi19 Jul 2023AY 2008-09
Section 143(3)Section 68

creditworthiness of the lenders were not proved by the assessee. Before the Ld. CIT(A), the assessee filed additional evidences in terms of Rule 46A of the Income Tax Rules containing the confirmation of accounts from the lenders, their ITR and annual reports. These additional evidences were duly forwarded

Assistant Commissioner of Income Tax, Circle 2(1), Raipur vs. Hi-Tech Abrasive Private Limited, Raipur

In the result, cross objection filed by the assessee is dismissed

ITA 142/RPR/2018[2014-15]Status: DisposedITAT Raipur19 Jul 2023AY 2014-15

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.142/Rpr/2018 (Assessment Year: 2014-2015) Acit, Circle-2(1), Raipur Vs Hi-Tech Abrasive Pvt. Ltd. 740, Sector-B, Urla Industrial Area, Raipur Pan No. :Aaach 5950 M & Cross Objection No.14/Rpr/2018 (Arising Out Of Ita No.142/Rpr/2018) (Assessment Year: 2014-2015) Hi-Tech Abrasive Pvt. Ltd. Vs Acit, Circle-2(1), Raipur 740, Sector-B, Urla Industrial Area, Raipur Pan No. :Aaach 5950 M (अपीलाथ" /Appellant) .. (""यथ" / Respondent) िनधा"रती क" ओर से /Assessee By : Shri R. B. Doshi, Ca राज"व क" ओर से /Revenue By : Smt. Ila M. Parmar, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 14/07/2023 घोषणा क" तार"ख/Date Of Pronouncement : 19/07/2023

For Appellant: Shri R. B. Doshi, CAFor Respondent: Smt. Ila M. Parmar, CIT-DR
Section 36Section 36(1)(va)Section 37Section 50

evidence produced by the assessee if any, without allowing the AO, proper opportunity to examine the same, thereby violating the provisions on law under Rule 46A of the IT Rules?” 6. “ Whether on points of law and on facts & circumstances of the case, the Ld. CIT(A), the order

The ACIT(Intel. Taxn.), Rajkot vs. Smt. Chandrika Bharat Ruparel, Rajkot

In the result, the appeal of the Department is dismissed

ITA 151/RJT/2021[2012-13]Status: DisposedITAT Rajkot19 Jul 2023AY 2012-13

Bench: Ms. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

For Appellant: Shri Mehul Ranpura, A.RFor Respondent: Shri Shramdeep Sinha, Sr. D.R
Section 250

facts and circumstances of the case and in law, the learned CIT(A) erred in admitting the additional evidences in contravention of Rule 46A of the Income-tax Rules, 1962 without appreciating the fact that the assessee failed to justify that her case was falling within the exception clause ... Rule 46A(1) of the IT. Rules. (2) On the facts and circumstances of the case and in law, the learned CIT(A) erred in admitting the additional evidences in contravention of Rule 46A of the Income-tax Rules, 1962 without appreciating the fact that the assessee had failed

The ACIT(International Taxation, Rajkot vs. Shri Bharat Champaklal Ruparel, Rajkot

In the result, the appeal of the Department is dismissed

ITA 150/RJT/2021[2012-13]Status: DisposedITAT Rajkot19 Jul 2023AY 2012-13

Bench: Ms. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

For Appellant: Shri Mehul Ranpura, A.RFor Respondent: Shri Shramdeep Sinha, Sr. D.R
Section 250

facts and circumstances of the case and in law, the learned CIT(A) erred in admitting the additional evidences in contravention of Rule 46A of the Income-tax Rules, 1962 without appreciating the fact that the assessee failed to justify that her case was falling within the exception clause ... Rule 46A(1) of the IT. Rules. (2) On the facts and circumstances of the case and in law, the learned CIT(A) erred in admitting the additional evidences in contravention of Rule 46A of the Income-tax Rules, 1962 without appreciating the fact that the assessee had failed

Shri Rajkot Distt. Co. Op. Bank Ltd., Rajkot-Gujarat vs. The Asstt. Commr. of Income Tax, Circle-1(2), Rajkot-Gujarat

In the result, the appeal of the assessee is allowed

ITA 288/RJT/2018[2014-15]Status: DisposedITAT Rajkot19 Jul 2023AY 2014-15

Bench: Shri Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

For Appellant: Shri D.M. Rindani, Ld. A.RFor Respondent: Shri B.D. Gupta, Ld. Sr. D.R
Section 250Section 30(1)(viii)Section 35(1)(viii)Section 36(1)(vi)Section 36(1)(viii)

learned Commissioner of Income Tax Appeals), Rajkot 3 has erred in not exercising his discretionary powers u/s 250 of the IT. Act and Rule 46A(6) of the T Rules of modification of deduction claim despite the fact that a plea to modify the legitimate claim u/s 36(1)(viii ... learned CIT(Appeal) has failed to appreciate that 3.1 Admission of modification of claim falls within the exception mentioned in Rule 46A(1) as also within discretionary powers of CITIA) u/s 250 of the T Act and Rule 46A(4) of 1. T. Rules. In wake of specific prayer made

Ameen Uddin, Bhopal vs. The ITO 3(4), Bhopal

ITA 101/IND/2023[2008-09]Status: DisposedITAT Indore19 Jul 2023AY 2008-09

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2008-09 Shri Ameen Uddin, I.T.O., 11, Kumharpura Road, 3(4), बनाम/ Galla Bazar, Bhopal Shahjahanabad, Vs. Bhopal (Assessee / Appellant) (Revenue / Respondent) Pan: Aaupu 8393 G Assessee By Shri S.S. Deshpande, C.A. Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 23.05.2023 Date Of Pronouncement 19.07.2023

Section 142(1)Section 144Section 147Section 148Section 271(1)(c)Section 69A

assessment u/s 144, Ld. AR submitted that during first appeal, the assessee filed an application dated 25.10.2017 to CIT(A)-II, Bhopal under Rule 46A of Income Tax Rules, 1962 for admission of additional evidences (Paper Book Page nos. 3 & 4). Thereafter, the CIT(A)-II, Bhopal called remand-report

Suraj Air Flow Engineers, Mumbai vs. The Assistant Commissioner of Income Tax, Circle-22(3), Mumbai

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

ITA 1386/MUM/2023[2014-2015]Status: DisposedITAT Mumbai18 Jul 2023AY 2014-2015

Bench: Shri Aby T Varkey & Shri Amarjit Singhsuraj Air Flow Engineers Vs. The Acit, Circle 22(3) 4, Ground Floor, Room No. 322, 3 Rd Floor, Akashdeep, 1St Road, T.P. Piramal Chambers, S. Vi, Santacruz (W) Lalbaug, Mumbai – 400 054 Mumbai – 400 012 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aacfs4159E Appellant .. Respondent [ Appellant By : None Respondent By : Suresh D. Gaikwad Date Of Hearing 10.07.2023 Date Of Pronouncement 18.07.2023 आदेश / O R D E R Per Amarjit Singh (Am): This Appeal Filed By The Assesse Is Directed Against The Order Passed By The Ld. Cit(A) Nfac, Dated 16.03.2023 For A.Y. 2014-15. The Assessee Has Raised The Following Grounds Before Us: “(A) Addition On Account Of Alleged Cash Credits- Rs.77,80,000/- 1. The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac) [Cit(A)] Erred On Facts & In Law In Confirming The Addition Made By The Assistant Commissioner Of Income Tax, Circle - 22(3), Mumbai (Ao) Of Rs.77,80,000/- On Account Of Alleged Cash Credits By Holding That The Appellant Did Not File Application For Admitting The Additional Evidences By Providing Reasonable Cause To Admit The Same. 2. The Learned Cit(A) Erred On Facts & In Law In Not Invoking The Powers Vested In Him Under Section 250(4) While Not Considering The Additional Evidences Furnished By The Appellant.

For Appellant: NoneFor Respondent: Suresh D. Gaikwad
Section 133(6)Section 143(2)Section 143(3)Section 250(4)Section 68

making submission by the lenders as discussed supra, however, the ld. CIT(A) has not considered the same on merit as provided in Rule 46A of the I.T. Rule 1962. We find that ld. CIT(A) has neither called any remand report from the assessing officer nor controvert the explanation

ACIT Circle-2(1), Ghaziabad vs. Manoj Raizada, Ghaziabad

In the result, the appeal of the Revenue and Cross Objection of the assessee both are dismissed

ITA 5/DEL/2021[2017-18]Status: DisposedITAT Delhi18 Jul 2023AY 2017-18

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2017-18 & Co No. 28/Del/2021 Asstt. Year: 2017-18

For Appellant: Shri Mayank Choudhary, AdvocateFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 37(1)Section 46ASection 9

No.5/ Del/2021 & CO No. 28/Del/2021 “1. The CIT(A) has erred in law and on facts in not appreciating and following the mandate of Rule 46A(1) of the I. T. Rules, 1962 which emphatically debars the assessee to produce any evidence, whether oral or documentary, other than the evidence ... that he was prevented by the sufficient cause to produce such evidence before the AO does not satisfy the conditions of Rule 46A(1) without substantiating it with relevant and cogent documentary evidence. 3. The CIT(A) has erred in law and on facts in admitting the additional evidence

JCIT Spl. Range-12, New Delhi vs. Arihanta Industries, Delhi

In the result, both the appeals of the Revenue are allowed

ITA 963/DEL/2019[2015-16]Status: DisposedITAT Delhi17 Jul 2023AY 2015-16

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

For Appellant: Sh. Sachit Jolly, AdvFor Respondent: Sh. P. Praveen Sidharth, CIT DR
Section 131Section 68Section 801CSection 80I

erred in not appreciating that the additional evidence was produced before him by the assessee without fulfilling the requirements of Rule 46A(1) of the IT Rules. 1962. The arguments that certificate dated 10.04.2010 and G.M.P certificate dated 30.07.2011 were not available with him at the time of assessment ... production of such old documents on the pretext its non-availability in the assessment proceedings does not fulfill any of the conditions of the Rule 46A(1) of the IT Rules, 1962. 2. The Ld. CIT(A) has erred in admitting the additional evidence by holding that the same

M/S Blue City Township & Colonizers, Amritsar vs. The Income Tax Officer, Amritsar

ITA 90/ASR/2017[2009-10]Status: DisposedITAT Amritsar14 Jul 2023AY 2009-10

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

Section 147Section 148Section 151Section 234ASection 69

filed before the AO in the assessment proceedings and is a fresh evidence filed for the first time in appeal proceedings under rule 46A of I T Rules. No reason was given by the appellant for non submission of this evidence before the AO in the assessment proceedings, therefore ... copy of letter of the retired cashier Sh Raj Kumar Gupta dated 09-04-2015 is refused to be admitted as additional evidence under rule 46A of I T Rules and is dismissed. 19 I.T.A. No. 90/Asr/2017 Blue City Township & Colonizers v. ITO Moreover, the said letter of the retired

V.B.Proteins (India) P.Ltd, Meerut vs. ITO, Ward-2(4), New Delhi

In the result, assessee’s appeal stands dismissed

ITA 5365/DEL/2017[2013-14]Status: DisposedITAT Delhi14 Jul 2023AY 2013-14

Bench: A.O. As Well As Cit(A), Meerut, Which Ought To Be Deleted.

For Appellant: NoneFor Respondent: Ms. Kajal Singh, Sr. DR
Section 145(3)Section 44A

referred in Appeal were not filed during the assessment proceedings and filed in appeal proceedings for the first time without filing the application under Rule 46A of the Income Tax Rules. In the above facts and circumstances, assessee is failed to prove the identity, creditworthiness and genuineness of the transaction ... authorities below. Furthermore, as noted by the ld. CIT (A), additional documents were filed for the first time without accompanying proper application under Rule 46A of the Income Tax Rules, 1962. Hence, ld. CIT (A) rightly rejected the same. In our considered opinion, the authorities below have passed reasonable order

Sandeep, Panipat vs. ITO, Ward- 4, Panipat

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

ITA 414/DEL/2019[2009-10]Status: DisposedITAT Delhi12 Jul 2023AY 2009-10
For Appellant: Shri J.B. Sharma, AdvocateFor Respondent: Ms. Kajal Singh, Sr. DR
Section 144Section 147Section 148

rightly rejected. 6. As regards merits of the case, before the ld. CIT (A), assessee has submitted his submissions and filed additional evidence under Rule 46A of the Income-tax Rules, 1962. The ld. CIT (A) asked for the remand report from the AO and reproduced the same

The ACIT (Central), Ujjain vs. M/S. Digiana Projects (P) Ltd., Indore

Appeal are allowed for statistical purposes as mentioned above

ITA 902/IND/2019[2016-17]Status: DisposedITAT Indore12 Jul 2023AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2016-17 Acit (Central), M/S. Digiana Ujjain Projects Private Limited, बनाम/ M-3, Sapna Chamber, 12/1, South Tukoganj, Indore Vs. (Revenue / Appellant) (Assessee / Respondent) Pan: Aadcd5465A Assessee By Shri Sudhir Padliya, Ca Revenue By Shri P.K.Mishra, Cit Dr Date Of Hearing 05.07.2023 Date Of Pronouncement 12.07.2023

Section 143(3)Section 68Section 69C

creditors from PAN data available in said report. (ii) It is further submitted that during first-appellate proceedings, the assessee filed additional evidences under Rule 46A of Income Tax Rules, 1962 and the CIT(A) called for remand-report from AO. Thereafter, the AO filed remand- report (copy available ... been drawn. After a careful consideration, we find that the assessee has filed additional evidences during first-appeal before CIT(A) in terms of Rule 46A on which the CIT(A) called remand-report from AO. Thereafter, the AO filed remand-report. But the CIT(A) has not uttered

DCIT, C-7, Jaipur vs. Bharat Mohan Raturi, Jaipur

In the result, the appeal of the Department is dismissed and that of the C

ITA 413/JPR/2022[2013-14]Status: DisposedITAT Jaipur11 Jul 2023AY 2013-14

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;djvihy la-@ITA No. 413/JP/2022 fu/kZkj.ko"kZ@AssessmentYear :2013-14 The DCIT Circle-7 Jaipur cuke Vs. Shri Bharat Mohan Raturi 161, Indira Colony, Bani Park Jaipur 302 015 (Raj) LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: AANPR 7066G vihykFkhZ@Appellant izR;FkhZ@Respondent CO No. 2/JP/2023 (Arising out of vk;djvihy la-@ITA No. 413/JP/2022 ) fu/kZkj.ko"kZ@AssessmentYear :2013-14 Shri Bharat Mohan Raturi 161, Indira

For Appellant: Shri Anil Goya, CA &For Respondent: Mrs. Runi Pal, Addl. CIT-DR
Section 148Section 54Section 54F

examine the conditions stipulated u/s 54 of the Act. Therefore, additional grounds of appeal accepted by the ld.CIT(A) was in violation of Rule 46A. C.O. No. 2/JP/2023 – A.Y. 2013-14 (Assessee) 1. Alternatively the AO has erred in disallowing deduction claimed by the assessee u/s 54F of Rs.94 ... examine the conditions stipulated u/s 54 of the Act. Therefore, additional grounds of appeal accepted by the Ld. CIT(A) was in violation of Rule 46A.’’ Submissions of the assessee on Ground No 1 of the department: 9 DCIT, CIRCLE-7, JAIPUR VS BHARAT MOHAN RATURI ‘On the facts

Nikhil Yogi, Delhi vs. DCIT Circle Int. Taxation-3(1)(1), Delhi

In the result, the appeal of the assessee is dismissed

ITA 670/DEL/2022[2017-18]Status: HeardITAT Delhi10 Jul 2023AY 2017-18

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2017-18 Nikhil Yogi, Vs. Dcit, 670, Block Gh-09, Circle- International Paschim Vihar, Taxation-3(1)(1) New Delhi – 110 087 New Delhi. Pan Abqpy8641L (Appellant) (Respondent)

For Appellant: NoneFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 133(6)Section 142(1)Section 143(3)Section 144Section 69A

Aggrieved, the assessee filed appeal before the Ld. CIT(A). During the appellate proceedings the assessee submitted additional evidence under Rule 46A of the Income Tax Rules, 1962. The Ld. CIT(A) obtained the Ld. AO’s report which he discussed in para 5.5 to 5.8 of his appellate order ... reproduced below:- “5.5 ...... The AO vide report dated 23.12.2021 has mentioned that the assessment order was passed after affording the appellant ample opportunities hence Rule-46A is not applicable in the case of the appellant while commenting on the merits of the additional evidences AO has mentioned that the appellant

ITO, New Delhi vs. M/S. Arjun Ispat India Pvt. Ltd., New Delhi

Accordingly, the grounds raised are allowed for

ITA 2725/DEL/2017[2012-13]Status: DisposedITAT Delhi10 Jul 2023AY 2012-13

Bench: Sh. M. Balaganesh & Sh.Anubhav Sharmaita No. 2725/Del/2017, A.Y. 2012-13 Income Tax Officer Vs. M/S. Arjun Ispat India P. Ward 3(2), Ltd. New Delhi Y-59, Loha Mandi, Naraina, New Delhi-110028 Appellant Respondent

Section 144Section 68

merit to the files of Ld. CIT(A) to take an additional evidence on record in accordance with law which includes an application under Rule 46A and calling remand report from the Ld. AO. Accordingly, the grounds raised are allowed for 2725/Del/2017 M/s. Arjun Ispat India P. Ltd. statistical purposes

Shri. Nitin Pal Singh, Jalandhar vs. Income Tax Officer Ward-3(3), Jalandhar

In the result, the appeal of the revenue bearing ITA No

ITA 65/ASR/2018[2013-14]Status: DisposedITAT Amritsar07 Jul 2023AY 2013-14

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

Section 143(3)Section 144Section 145(3)Section 250(6)Section 68

when the assessee refused to receive the notices issued, during the course of assessment proceedings and also didn’t refill the conditions as per Rule 46A of the Income Tax Rules, 1962. I.T.A. Nos.46&65/Asr/2018 Assessment Year: 2013-14 3 2. The Ld. CIT(A) has erred in admitting additional ... total addition of Rs. 1,50,00,000/-, after admission of additional evidence, which was not in accordance with the provisions of Rule 46A of the I.T. Rules, 1962. 4. That on the facts and in the circumstances of the case, the Ld. CIT(A) has erred

Income Tax Officer Ward-3(5), Jalandhar vs. Shri Nitin Pal Singh, Jalandhar

In the result, the appeal of the revenue bearing ITA No

ITA 46/ASR/2018[2013-14]Status: DisposedITAT Amritsar07 Jul 2023AY 2013-14

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

Section 143(3)Section 144Section 145(3)Section 250(6)Section 68

when the assessee refused to receive the notices issued, during the course of assessment proceedings and also didn’t refill the conditions as per Rule 46A of the Income Tax Rules, 1962. I.T.A. Nos.46&65/Asr/2018 Assessment Year: 2013-14 3 2. The Ld. CIT(A) has erred in admitting additional ... total addition of Rs. 1,50,00,000/-, after admission of additional evidence, which was not in accordance with the provisions of Rule 46A of the I.T. Rules, 1962. 4. That on the facts and in the circumstances of the case, the Ld. CIT(A) has erred