“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

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

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

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, Circle-1, Nashik vs. Taparia Tools Limited, Nashik

In the result, both the appeal of the Revenue as well as Cross Objection of the assessee are allowed for statistical purposes as per the terms indicated above

ITA 1337/PUN/2025[2017-18]Status: DisposedITAT Pune10 Dec 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1337/Pun/2025 Assessment Year : 2017-18

For Appellant: Shri Amit BobdeFor Respondent: Shri Viral Shah

Section 142(1)Section 147Section 148Section 37(1)

However, no such GST closure report dated 30th December 2021 is on record. If this was additional evidence, then the Ld.CIT(A), as per rule 46A, ought to have forwarded the same to the AO for the comments. The failure of ld.CIT(A) to not follow the procedure laid down ... Rule 46A renders the order illegal and liable to be quashed. It is seen that in the paper book submitted by the assessee, there are two documents- one dated 24.12.2021 (page no. 2356 of the asseesse's paper book) and other is dated 27.04.2023 (page nos 2357-2359). The document

Income Tax Officer, Ward-1(1), Hyderabad vs. Adhithi Infra Projects Private Limited, Hyderabad

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

ITA 808/HYD/2025[2013-14]Status: DisposedITAT Hyderabad10 Dec 2025AY 2013-14

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdia

For Appellant: N ON EFor Respondent: Shri S. Arun Kumar, Sr. DR

Section 115JSection 143(2)

appellate order with out obtaining the remand report on additional evidence filed by the assessee in the second instance, which is violation of Rule 46A of IT Rules, 1962. The Ld.CIT(A) erred in observing tha‘ assessee’s claims whereas the failure was on the assessee to submit response ... multiple opportunities provided. it is failure of AO in not rebutting . The Ld. CIT(A) failed to comply with the mandatory procedure prescribed under Rule 46A(3), which requires the Assessing Officer to be given a reasonable opportunity to rebut or cross-examine any additional evidence submitted by the assessce

Income Tax Officer, Ward-1, Warangal vs. Shiva Kumar Thota, Warangal

In the result, the primary objection filed by the assessee vide his letter, dated 02/06/2025 is allowed while for the appeal filed by

ITA 996/HYD/2024[2017-18]Status: DisposedITAT Hyderabad10 Dec 2025AY 2017-18

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.996/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Income Tax Officer, Vs. Shiva Kumar Thota, Ward-1, Warangal. Warangal. Pan: Aaopt4519M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By: Mrs. U. Mini Chandran, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 18/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Revenue Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2024 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 26/05/2023 For The Assessment Year 2017-18. The Revenue Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: Mrs. U. Mini Chandran

Section 147Section 148Section 148ASection 43BSection 68

ought to have given an opportunity to the AO on the additional evidences and submissions made before the Appellate authority under Rule 46A of the Income Tax rules prior to allowing the appeal 3. The Id CIT(A) ought to have called for a remand report from ... said submissions and evidences filed as per Rule 46A of the Income Tax Rules. 4. Any other grounds that may arise during the hearing will be submitted before Hon’ble ITAT with kind permission.” 2. Also, the revenue has raised an additional grounds of appeal, as under: “Notice

Umar Daraj, Meerut vs. ITO Ward-1(2)(4), Meerut

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

ITA 3095/DEL/2025[2015-16]Status: DisposedITAT Delhi10 Dec 2025AY 2015-16

Bench: Shri S.Rifaur Rahman & Shri Yogesh Kumar U.S.Umar Daraj, Vs. Ito, Ward 1(2)(4), 153/1, Hapur Road, Meerut. Umar Nagar, Meerut – 250 001 (Uttar Pradesh). (Pan : Ainpd8766H) (Appellant) (Respondent) Assessee By : Shri Sumit Lal Chandani, Advocate Revenue By : Shri Dayainder Singh Sidhu, Citdr Date Of Hearing : 17.09.2025 Date Of Order : 10.12.2025 O R D E R Per S. Rifaur Rahman:

For Appellant: Shri Sumit Lal Chandani, AdvocateFor Respondent: Shri Dayainder Singh Sidhu, CITDR

Section 142(1)Section 143(3)Section 148Section 151Section 40A

Assessing Officer/CTT(A) failed to provide reasonable opportunity to the appellant. 11. That CIT(A) has erred in rejecting the additional evidence submitted under Rule 46A without proper examination and without recording a valid reason, thereby depriving the appellant of a fair hearing and violating the principles of natural justice

Income Tax Officer, Ward- 5(1), C.R. Building vs. Borze India Private Limited, Gazipur, Delhi

The appeal of the revenue is allowed for statistical purpose and issue with regard to admissibility of

ITA 3845/DEL/2024[2017-2018]Status: DisposedITAT Delhi10 Dec 2025AY 2017-2018

Bench: Shri Anubhav Sharma & Shri Manish Agarwalito, Ward 5(1) Vs. Borze India Pvt. Ltd. R. No. 379, C.R. Building, 105, Vardhman Master I.P. Estate, Plaza, Gazipur, New Delhi – 110002 Delhi – 110096 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaecb8066E Appellant .. Respondent

For Appellant: Sh. Shantanu Kanungoo, AdvFor Respondent: Sh. Krishna Kumar Ramawat, Sr

Section 143(3)

merits, department has raised ground no. 2 that the additional evidences were admitted at the stage of Ld. First Appellate Authority without complying with Rule 46A of the Income Tax Rules. 3. Ld. Counsel for assessee has vehemently argued that as the submissions were lengthy and the paper book ... unable to upload the same online and AO was not ready to accept the physical copies. Attention was drawn to copy of application under Rule 46A available at page 129-130 of the paper book wherein similar facts were asserted. The Ld. Counsel submitted that the additional evidences were primarily

Dharmavir Kumar, Patna vs. Dc/Ac Circle 4, Patna

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

ITA 70/PAT/2025[2016-17]Status: HeardITAT Patna09 Dec 2025AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Dharmavir Kumar Dc/Acit, Circle-4, C/O Naseeb Prasad, Income Tax Department, Lok Paithaninathpur,Narayan Chak, Nayak Jai Prakash Bhavan, New Vs. Phulwari. Dak Bunglow Road, Bihar-800002 Patna-800001, Bihar (Appellant) (Respondent) Pan No. Avzpk4382P Assessee By : Shri Sudeep Sinha, Ar Revenue By : Shri Md. A.H. Chowdhary, Dr Date Of Hearing: 26.11.2025 Date Of Pronouncement: 09.12.2025

For Appellant: Shri Sudeep Sinha, ARFor Respondent: Shri Md. A.H. Chowdhary, DR

Section 143(3)Section 263Section 48Section 49Section 50CSection 96

assessee. The learned CIT (A) did not adjudicate the issue by admitting the documents filed by the assessee as additional evidences under Rule 46A of the Income Tax Rules, 1962 and thus dismissed the appeal of the assessee. 2.3. After hearing the rival contentions and perusing the materials available

Krishna Mohan, Patna vs. ACIT, Circle-14, Patna

In the result, the appeal of the assessee is allowed

ITA 476/PAT/2025[2017-18]Status: HeardITAT Patna09 Dec 2025AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Krishna Mohan Prop-M/S Maa Ambey Traders, Acit, Circle-14, Patna Maurari Complex, Karbigahiya, Patna, Bihar Vs. Patna-800001, Bihar (Appellant) (Respondent) Pan No. Ahupm5205C Assessee By : Shri Manish Rastogi, Ar Revenue By : Shri Md. Ah Chowdhary, Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 09.12.2025

For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Md. AH Chowdhary, DR

Section 143(2)Section 143(3)Section 69A

during the demonetization period. The assessee has also challenged the order of learned CIT (A) on the ground that the admission of additional under Rule 46A without referring the same to the learned AO. Krishna Mohan; A.Y. 2017-18 2.1. The facts in brief are that the assessee filed ... Govt. We further note that the learned CIT (A) dismissed the appeal on the ground that the assessee has furnished the additional evidences under Rule 46A which were not maintainable as assessee was allowed sufficient time to file these papers/documents during the assessment proceedings. We have examined these evidences

Rajwant Kaur, Pehowa, Kurukshetra vs. ITO, Ward 3, Kurukshetra

In the result, the delay is condoned and the appeal is treated as allowed for statistical purposes

ITA 1023/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh09 Dec 2025AY 2012-13

Bench: The Tribunal With A Delay Of 408 Days. Along With The Appeal, The Assessee Has Filed An Application Seeking Condonation Of Delay. In The Condonation Petition, The Assessee Has Explained That She Is A Farmer By Occupation, Residing In A Rural Area & Has Very Limited Knowledge Of Income Tax Laws As Well As Online Procedures. It Has Been Stated That She Was Not Aware Of The Requirement To Check Or Respond Through The Income-Tax E-Filing Portal & Came To Know About The Demand Only Upon Receipt Of A Physical Notice From The Department. Thereafter, She Immediately Sought Professional Assistance. The Delay, According To The Assessee, Is Wholly Unintentional & Caused Due To Circumstances Beyond Her Control.

For Appellant: Shri Rajeev Sachdeva, C.AFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 148

objections, incorrect appreciation of facts relating to transfer of ancestral agricultural land without consideration, and denial of opportunity for furnishing additional evidence under Rule 46A. 6. The impugned order reveals that although five notices were issued to the assessee on different dates, no effective submissions were received except a request ... adjudicated the grounds on merits, nor has there been any consideration of the assessee’s request seeking admission of additional evidence under Rule 46A. 7. We have heard the rival contention and perused the material available on the record. In the present case we find that the assessee, being

Dilip Kumar Pramanik, Kolkata vs. I.T.O., Ward - 25(1), Kolkata

In the result, all the three appeals filed by the assessee are partly allowed for statistical purposes

ITA 1581/KOL/2025[2018-2019]Status: DisposedITAT Kolkata09 Dec 2025AY 2018-2019

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 142(1)Section 250Section 272Section 273B

heard to make any further submission it wants to make in support of its grounds of appeal and shall not seek unnecessary adjournments and rule 46A of the I.T. Rules, 1962 shall also be followed ITA Nos.: 1579, 1580 & 1581/KOL/2025 Assessment Year: 2018-19 Dilip Kumar Pramanik. and an opportunity

Dilip Kumar Pramanik, Kolkata vs. I.T.O., Ward - 25(1), Kolkata

In the result, all the three appeals filed by the assessee are partly allowed for statistical purposes

ITA 1580/KOL/2025[2018-2019]Status: DisposedITAT Kolkata09 Dec 2025AY 2018-2019

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 142(1)Section 250Section 272Section 273B

Dilip Kumar Pramanik, Kolkata vs. I.T.O., Ward - 25(1), Kolkata

In the result, all the three appeals filed by the assessee are partly allowed for statistical purposes

ITA 1579/KOL/2025[2018-2019]Status: DisposedITAT Kolkata09 Dec 2025AY 2018-2019

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 142(1)Section 250Section 272Section 273B

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Aadhitya Fincorp Pvt Ltd, Chennai

The appeal of the revenue is dismissed

ITA 659/CHNY/2025[2015-16]Status: DisposedITAT Chennai09 Dec 2025AY 2015-16

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Ms. E. Pavuna Sundari, C.I.TFor Respondent: Ms. N. V. Lakshmi, Advocate

Section 132Section 132(4)Section 144Section 145(3)Section 153CSection 40A(3)Section 69A

income, on the ground that the accounts were reconciled & recomputed by the assessee at the appellate without giving opportunity to the AO Under Rule 46A of Income Tax Rules? 2.1 The Ld. CIT(a) erred in allowing the assessee’s reconciling of sundry parties as new claim during the appellate ... Rs.3,75,00,000/- was collected and returned by assessee as collection agent for M/s.Sree Gokulam Chits & Finance without opportunity of verification as per Rule 46A. 2.2 The Ld.CIT(A) erred in not observing that the statement disclosing income made under section 132(4) has evidentiary value and any declaration

DCIT, Central Circle-2(2) Chennai, Chennai vs. Red Carpet Studio, Chennai

ITA 621/CHNY/2025[2016]Status: DisposedITAT Chennai09 Dec 2025

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:621/Chny/2025 निर्धारण वर्ष / Assessment Year: 2016-17 Dcit, Central Circle -2(2), Chennai. Red Carpet Studio, Vs. No.3, Good Ville Court, 16, Bagavatham Street, T.Nagar, Chennai – 600 017. [Pan:Aarfr-5627-H] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Ms. E. Pavuna Sundari, C.I.T. प्रत्यर्थी की ओर से/Respondent By : Ms. N. V. Lakshmi, Advocate सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement 06.10.2025 09.12.2025 आदेश /O R Der Per S. R. Raghunatha, Am : The Present Appeal Is Filed By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals), Chennai 19, [In Short 'Ld.Cit(A)'] Dated 20.12.2024 For The Assessment Year [‘A.Y.'] 2016-17 Arising Out Of The Order Of The Assessing Officer Passed U/S.144 Of The Income Tax Act, 1961 (In Short ‘The Act') Dated 29.12.2017. 2. The Grounds Of Appeal Raised By The Revenue Are Reproduced Below: :-2-:

For Appellant: Ms. E. Pavuna Sundari, C.I.TFor Respondent: Ms. N. V. Lakshmi, Advocate

Section 132Section 144Section 153A

ground that the net profit was recomputed based on the revised books filed by the assessee without giving opportunity to the AO under Rule 46A of Income Tax Rules? 3. The Ld. CIT (A) erred in holding that sworn statement of shri P.Ramesh, Managing Partner of M/s. Red Carpet Studios

Deputy Commissioner of Income Tax, Agra vs. Adity Pandey, Agra

In the result, both the appeals ITA No

ITA 384/AGR/2025[2022-23]Status: DisposedITAT Agra08 Dec 2025AY 2022-23

Bench: : Shri M. Balaganesh & Shri Sunil Kumar Singh

Section 143(2)Section 144Section 250Section 271ASection 69ASection 80C

submitted before the Assessing Officer during the assessment proceedings by the assessee. Thus, the CIT(A) has failed to adhere to the provisions of Rule 46A, which mandates that an opportunity must be provided to the Assessing Officer for giving his own perspective on additional evidences before being considered ... submitted before the Assessing Officer during the assessment proceedings and submitted that the ld. CIT(Appeals) has passed the impugned order in violation of Rule 46A of the Income-tax Rules, 1962. 8. Learned AR has submitted that the revenue had ample opportunity to rebut the letter issued

Deputy Commissioner of Income Tax, Agra vs. Aditya Pandey, Agra

In the result, both the appeals ITA No

ITA 383/AGR/2025[2022-23]Status: DisposedITAT Agra08 Dec 2025AY 2022-23

Bench: : Shri M. Balaganesh & Shri Sunil Kumar Singh

Section 143(2)Section 144Section 250Section 271ASection 69ASection 80C

Jws Multi State Co-Operative Housing Society Limited, Delhi vs. ITO Ward 60(5), Delhi

In the result, appeal of the assessee in ITA No

ITA 3260/DEL/2025[2016-17]Status: DisposedITAT Delhi08 Dec 2025AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Sanjay Joshi, CAFor Respondent: Ms. Ankush Kalra, Sr. DR

decided the issue without appreciation of facts and evidence brought on his record. The ld. CIT(A) has accorded primacy to the technicality of Rule 46A of the I.T. Rules and has ignored the principles of substantive justice. In view of the above facts and circumstances and in the interest

Income Tax Officer-2(1)(4), Rudrapur vs. Swarnim Promoters & Developers, Rudrapur

In the result, the appeal of the Revenue is dismissed

ITA 55/DDN/2025[2018-19]Status: DisposedITAT Dehradun05 Dec 2025AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalincome Tax Officer-2(1)(4), Swarnim Promotoers & Rudrapur. Developers, Vs. Mandi Parisar Kichha Road, Rudrapur, Uttarakhand. Pan: Abqfs9375M (Appellant) (Respondent) Assessee By Shri Amit Goel, Ca & Shri Pranav Yadav, Adv. Department By Shri Amar Pal Singh, Sr. Dr Date Of Hearing 11/09/2025 Date Of Pronouncement 05/12/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Revenue Against The Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (‘The Cit(A) In Short) Passed U/S 250 Of The Income Tax Act, 1961, Dated 06.02.2025 For Assessment Year 2018-19. 2. The Brief Facts Of The Case Are That The Assessee Is A Partnership Firm Engaged In The Business Of Real Estate. The Return Of Income Was E-Filed On 17.10.2018 Declaring Total Income At Rs.2,89,400/-. The Case Of The Assessee Was Selected For Complete Scrutiny & The Assessing Officer Has Computed The Total Income At Rs.1,27,38,630/- Vide Order Passed U/S 143(3) R.W.S. 144B Of The Act Dated 02.06.2011 By Making The Following Additions/Disallowances:

Section 143(3)Section 250Section 37Section 68

hand, the Ld. SR. DR submits that assessee has filed additional details before the Ld. CIT(A) who had not followed the process of Rule 46A of Income Tax Rules, 1962 and not confronted the documents filed from the AO and accordingly, it is a violation of Rule 46A

DCIT, Pune vs. Quick Heal Technologies Limited, Pune

In the result, the appeal of the Revenue is dismissed

ITA 2031/PUN/2025[2014]Status: DisposedITAT Pune05 Dec 2025

Bench: Shri Manish Borad & Ms. Astha Chandra

For Appellant: Shri Nikhil MuthaFor Respondent: Shri Bharat Andhale

Section 143(3)Section 14ASection 17Section 263

first time before the Id. CIT(A) and therefore, the same would fall in the category of additional evidences within the meaning of Rule 46A of the 1.T. Rules. 2. On the facts and circumstances of the case and in law, the ld. CIT(A) erred in admitting ... rule (1) of Rule 46/1 under which it merited admission as additional evidence, thereby violating the mandate contained in sub- rule (2) of Rule 46A. 3. On the facts and circumstances of the case and in law, the ld. CIT(A) erred in admitting the additional evidences furnished

Dy Commissioner of Income Tax Circle 5 Pune, Pune vs. Dipti Narendra Lulla, Pune

ITA 1065/PUN/2025[2018-19]Status: DisposedITAT Pune05 Dec 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

Section 143(2)

first time before the Ld. CIT(A) and therefore, the same would fall in the category of additional evidences within the meaning of Rule 46A of the 1.T. Rules. 1.2 On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in admitting ... additional evidences furnished by the assessee without recording a clear finding as to the circumstances as detailed in sub-rule (1) of Rule 46A under which it merited admission as additional evidence and admitting the same without providing an opportunity to the AO, thereby violating the mandate contained

ITO., Ward-9(1), Hyderabad vs. Manisha Dixit, Vanasthalipuram

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

ITA 735/HYD/2025[2021-22]Status: HeardITAT Hyderabad05 Dec 2025AY 2021-22

Bench: Shri Ravish Sood

For Appellant: Shri Rama Murthy T, CAFor Respondent: Dr. Narendra Kumar Naik, CIT

Section 143(2)Section 143(3)Section 69C

assessee preferred an appeal before the Ld. CIT(A). Before the Ld. CIT(A), the assessee filed additional evidences under Rule 46A of the Income Tax Rules, 1962 (“the Rules”), which were admitted by the Ld. CIT (A). The Ld. CIT(A) thereafter called for a remand report from ... addition. The Ld. DR also submitted that although the assessee furnished documents before the Ld. CIT(A) and the same were admitted under Rule 46A of the Rules, the Ld. CIT(A) was duty- bound to verify all the documents relating to all thirteen parties. Instead