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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

Santosh Kumar Shukla, Lucknow vs. Assessment Unit, NFAC

ITA 400/LKW/2025[2015-16]Status: DisposedITAT Lucknow21 Nov 2025AY 2015-16

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2015-16 Santosh Kumar Shukla V. The Assessment Unit 11A/141, Vrindavan Colony Nfac Lucknow (U.P) Tan/Pan:Bawps5372J (Appellant) (Respondent) Appellant By: Shri Shalabh Singh, Advocate Respondent By: Shri Amit Kumar, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 12.03.2025 Passed By The National Faceless Appeal Centre (Nfac), Delhi For Assessment Year 2015-16. 2. The Brief Facts Of The Case Are That The Assessee Was An Employee Of Planning Research & Action Division Of State Planning Institute, Since 1993. The Case Of The Assessee Was Reopened Under Section 147 Of The Income Tax Act, 1961 (Hereinafter Called “The Act’) After Issuing Notice Under Section 148A(B) Of The Act, Vide Dated 16.03.2022 For The Reason That The Assessee Had Made Cash Deposits/Time Deposits In His Bank Account. In Response To Notice Under Section Under Section 148 Of The Act, The Assessee Filed His Return Of Income For The Year Under Consideration On 29.04.2022, Declaring A Total Income Of

For Appellant: Shri Shalabh Singh, AdvocateFor Respondent: Shri Amit Kumar, D.R
Section 144BSection 147Section 148Section 148ASection 149Section 149(1)(b)Section 151ASection 69Section 69A

exercising its jurisdictional right and enabling powers vested as first Appellate authority instead of taking a super technical and mechanical view of Rule 46A(1) not in its purposive sense especially since the said Rules do not take away the inherent powers of the CIT Appeals to verify summon ... make such further inquiry as he thinks fit or to direct the AO, to make further inquiry and report the result to him. The Rule 46A(4) clarifies that nothing contained in rule 46A shall affect the CIT(A)'s power to direct the production of any document

Manjeet Kaur Kamboj, Yamuna Nagar Haryana vs. ITO Ward-2, Yamuna Nagar Haryana

In the result, appeal of the Assessee is dismissed

ITA 550/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh21 Nov 2025AY 2012-13

Bench: Shri Laliet Kumat & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 550/Chd/2025 िनधा"रण वष" / Assessment Year : 2012-13 Manjit Kaur Kamboj, Ito Ward-2, Lotus Valley Public School, बनाम Yamuna Nagar, Sector – 18, Huda, Haryana Vs. Yamunanagar, Haryana "ायी लेखा सं./Pan No. Abmpk5213G अपीलाथ"/Appellant ""थ"/Respondent ( Physical Hearing ) िनधा""रती की ओर से/Assessee By : Ms. Meenal Goyal, Ca & Sh. Abhinav Jain, Adv. राज" की ओर से/ Revenue By : Dr. Ranjit Kaur, Addl. Cit, Sr. Dr सुनवाई की तारीख/Date Of Hearing : 18.11.2025 उदघोषणा की तारीख/Date Of Pronouncement : 20.11.2025 आदेश/Order Shri Laliet Kumar: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 21.03.2024 Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi For A.Y. 2012-13. 2. Grounds Of Appeal, As Taken By The Assessee In Form 36, Are Reproduced As Under:

For Appellant: Ms. Meenal Goyal, CA and Sh. Abhinav Jain, AdvFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 143(3)Section 148Section 2(14)Section 2(14)(iii)Section 250

well as the Ld. AO failed to even address comprehensive documentary evidences and additional evidences under Rule 46A, placed before both authorities demonstrating that the land sold by the Appellant is a rural agricultural land and hence not a capital asset. 3 For that on the facts and circumstances

Assistant Commissioner of Income Tax, Central Circle, Bellary vs. M/S Virgo Properties Private Limited, Chennai

ITA 1181/BANG/2025[2013-14]Status: DisposedITAT Bangalore21 Nov 2025AY 2013-14

Bench: Shri.Laxmi Prasad Sahu & Shri. Keshav Dubey

Section 142(1)Section 143(3)Section 148

respectively on the basis of additional evidence filed by the assesse during appellate proceedings without following the procedure laid down in Rule 46A of the IT Rules? (D) Appellant craves leave to modify, amend or revise the above grounds of appeal and add further grounds of appeal, if necessary ... tantamount to additional evidences. Accordingly, the CIT(A) was bound to furnish the additional evidences to the AO as provided under Rule 46A and called for a remand report on the same. Thus, the principle of natural justice was rendered to the AO. 8. Further, the reassessment proceedings were initiated

DCIT 3.2.1, Mumbai vs. The New India Assurance Co Limited, Mumbai

ITA 2827/MUM/2024[2017-18]Status: DisposedITAT Mumbai21 Nov 2025AY 2017-18
For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal Kumar&
Section 115JSection 143(3)Section 147Section 148

IN THE INCOME TAX APPELLATE TRIBUNAL "I" BENCH, MUMBAI SHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER

Deputy Commissioner of Income Tax, New Delhi vs. Global Agro Corp, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 4544/DEL/2024[2017-18]Status: DisposedITAT Delhi21 Nov 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2017-18] Dcit Vs Global Agro Corp, Room No.1704, Plot No.07,1St Floor, E-2 Block, Central Market West Civic Centre, Avenue Road, New Delhi-110002. West Punjabi Bagh, New Delhi-110026. Pan-Aakfg2650A Appellant Respondent Revenue By Shri Dheeraj Kumar Jaiswal, Sr.Dr Assessee By Shri Nitin Gulati, Ca Date Of Hearing 17.09.2025 Date Of 21.11.2025 Pronouncement Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Revenue Against The Order Dated 19.07.2024 Passed By Ld. Commissioner Of Income Tax (A), [“Ld.Cit(A)”], National Faceless Appeal Centre (“Nfac”), Delhi In Appeal No. Cit(A), Delhi-15/10990/2019-20 U/S 250 Of The Income Tax Act,1961 [“The Act”] Arising Out Of The Assessment Order Dated 31.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Is A Partnership Firm, Engaged In Export Of Rice & E-Filed Its Return Of Income On 28.09.2017 Declaring Income At Inr 66,28,650/-. The Case Was Selected Through Cass & After Considering The Submissions Made By The Assessee From Time To Time, Assessment Was Completed U/S 143(3) Vide Assessment Order Dated 31.12.2019 Wherein Following Additions Were Made:

Section 115BSection 143(3)Section 145(3)Section 250Section 40A(2)(b)Section 68

circumstances of the case and provision of law, the Ld. CIT(A) has erred in not providing an opportunity to the Assessing Officer under Rule 46A to give comments/counter the issues raised. In Ground of appeal No.1, Revenue has challenged the 5. addition of INR 1,57,66,969/- made

Sunil Madhyani, Durg vs. Deputy Commissioner of Income Tax, Circle -1(1), Bhilai

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

ITA 586/RPR/2025[2017-2018]Status: DisposedITAT Raipur20 Nov 2025AY 2017-2018

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.586/Rpr/2025 "नधा"रण वष" / Assessment Year : 2017-18 Sunil Madhyani Ward No.24, Behind Hotel Malwa Durg (C.G.)- 491 001 Pan: Apipm9839G

For Appellant: Shri Rakesh Dhody, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 133ASection 142(1)Section 144BSection 147Section 148Section 2(22)(e)

ground verification by calling for a remand report from the A.O shall be relevant for adjudication on merits as per law in terms with Rule 46A(3) of the I.T Rules, 1962. We herein admit the additional evidences a/w. application under Rule 29 of the ITAT Rules, 1963 and order

DCIT-1(1), Bhilai vs. Saligram Tripathi, Durg

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

ITA 582/RPR/2025[2013-14]Status: DisposedITAT Raipur20 Nov 2025AY 2013-14

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.582/Rpr/2025 "नधा"रण वष" / Assessment Year : 2013-14 The Deputy Commissioner Of Income Tax-1(1), Bhilai (C.G.)

For Appellant: None (Petition filed)For Respondent: Shri Ram Tiwari, CIT-DR
Section 69

first time at the appellate stage, without providing the adequate opportunity to the AO for examination of the additional evidences in view of Rules 46A of the IT Rules,1962. 4. Whether, on the facts and in the circumstances of the case, and in law, the ld.CIT(A) was justified ... should be condemned unheard is the basic canon principles of natural justice and accordingly we find merit in the contentions of the assessee that Rule 46A of the Income Tax Rules cannot be override the principles of natural justice. Hence we are of the view that the learned

Income Tax Officer, Risali, Bhilai vs. Amit Gautam, Rajnandgaon

ITA 566/RPR/2025[2018-19]Status: DisposedITAT Raipur20 Nov 2025AY 2018-19

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 566/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19)

For Appellant: None (adjournment application)For Respondent: Shri Ram Tiwari, CIT-DR
Section 144Section 147Section 148Section 250Section 69C

examine the same by calling for a remand report, thereby violating the principles of natural justice and the mandate of Rule 46A of the Income-tax Rules, 1962? (2) Any other ground which may be adducted at the time of hearing. 3. The brief facts of the case are that ... been exercised or deemed necessary by the first appellate authority, thereby have grossly violated the principle of natural justice and the provisions of Rule 46A of the Income Tax Rules,1962. In terms of such submissions, it was the prayer by Ld. CIT-DR that the appeal filed

Harihar Prasad, Patna vs. ITO Ward 4 (4), Patna

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

ITA 268/PAT/2023[2017-18]Status: DisposedITAT Patna20 Nov 2025AY 2017-18

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(2)Section 143(3)Section 250Section 54BSection 54FSection 96

afresh after considering the evidence to be filed by the assessee and after granting an opportunity of being heard to the Ld. AO under rule 46A of the I.T. Rules, 1962, if required as these documents were not filed before the Ld. AO and are in the nature of additional

Hubspire, Ernakulam vs. Assessing Officer, Ernakulam

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

ITA 781/COCH/2025[2020-2021]Status: DisposedITAT Cochin19 Nov 2025AY 2020-2021

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm Assessment Year: 2020-21 Hubspire .......... Appellant H2/2041, St. Benedict Extention Road Ernakulam North, Kochi 682018 [Pan: Aahfh3670C] Vs. The Income Tax Officer, Ward-1, Kochi ......... Respondent Assessee By: ------- None ------- Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 07.11.2025 Date Of Pronouncement: 19.11.2025

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 148Section 148A

filed before the CIT(A) who vide the impugned order had refused to admit the additional evidence on the ground that no application under rule 46A of the I.T. Rules was made for admission of the additional evidence. 4. Being aggrieved, the appellant is in appeal before this Tribunal ... ground that no application for admission of additional ground was filed by the appellant. We are of the considered opinion that formal application under rule 46A is only a mere procedural functionality. The CIT(A) ought to have admitted the additional evidence after complying with the provisions of rule 46A

Income Tax Officer Ward 2(2) Kalyan, Kalyan vs. Jaikumar Amarlalphagwani, Ulhasnagar

In the result, Revenue’s appeal is allowed for statistical purposes

ITA 6729/MUM/2024[2018-19]Status: DisposedITAT Mumbai19 Nov 2025AY 2018-19

Bench: Shri Narender Kumar Choudhryshri Prabhash Shankarassessment Year: 2018-19 Income Tax Officer Ward Jaikumar 2(2) Kalyan Amarlalphagwani Income Tax Office Mohan Plaza Flat No. 703, 7Th Floor, Wayale Nagar Vs. Milan Palace A Wing Khemani, Nr Ruhani Satsang Hall Ulhasnagar, Mumbai- 421002 Pan: Amnpp8597Q (Appellant) (Respondent) Present For: Assessee By : Shri Sunil Makhija A/W Ms. Manisha Ghind Revenue By : Shri Leyaqat Ali Aafaqui, Sr.D.R. Date Of Hearing : 22.08.2025 Date Of Pronouncement : 19.11.2025 O R D E R Per : Narender Kumar Choudhry:

For Appellant: Shri Sunil Makhija a/wFor Respondent: Shri Leyaqat Ali Aafaqui, Sr.D.R
Section 250Section 46A(3)

therefore the Revenue has challenged the decision of the Ld. Commissioner qua admitting and considering the additional evidences, as against the provisions of rule 46A(3) of the rules. 5 Jaikumar Amarlal Phagwani 10.2 Provisions of Rule 46A, mandates that the Assessee shall not be entitled to produce before ... assessment order without giving sufficient opportunity to the Assessee to adduce the evidence relevant to the grounds of appeal. Thus, the exceptions provided in rule 46A(1) of the rules, are not applicable to the case of the Assessee. 10.4 Further, in rule 46A(2) it is prescribed that

Jatin, Sonipat, Haryana vs. ITO Ward 2, Sonipat Haryana

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

ITA 1750/DEL/2025[2017-2018]Status: DisposedITAT Delhi19 Nov 2025AY 2017-2018

Bench: Shri Mahavir Singh & Shri Krinwant Sahay[Assessment Year: 2017-18]

Section 144

during the course of assessment proceedings. Nor did the assessee file any submissions supported by proper evidence along with a petition under Rule 46A for admission of evidence in the appellate proceedings. The assessee has not controverted the findings of the AO supported by proper evidence. I also find that

Satbir Sagwal, Karnal vs. Income Tax Officer, Ward-4, Karnal

ITA 1617/DEL/2024[2011-12]Status: DisposedITAT Delhi19 Nov 2025AY 2011-12

Bench: Sh. Sudhir Kumar & Sh. Brajesh Kumar Singhassessment Year: 2011-12 Satbir, Sagwal C/O Tej Mohan Vs Income Tax, Officer Singh H.No.527, Sector 10D Ward-4 Karnal Haryana Chandigarh 160011 Pan No. Bdops3759N (Appellant) (Respondent)

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 263Section 69

passed u/s 147 is illegal, arbitrary and unjustified. 4. That Ld. Commissioner of Income Tax (Appeals) has erred in rejecting the application filed under Rule 46A of the Act for admission of additional evidence which evidence goes to the root of the matter and as such the order passed

Assistant Commissioner of Income Tax, Central Circle, Belagavi vs. M/S Potdar Brothers, Belagavi

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

ITA 180/PAN/2025[2022-23]Status: DisposedITAT Panaji18 Nov 2025AY 2022-23

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]
Section 132Section 133ASection 138Section 143(1)Section 143(3)Section 147Section 148Section 246ASection 250Section 253(2)

course of hearing, the Ld. DR at the very outset has commonly alleged that; the impugned orders not only suffered from compliance of rule 46A of Income Tax Rules, 1962 [‘IT- Rules’ hereinafter] but transgressed the provisions of s/s (1) of section 251 and s/s (6) of section ... these additions were deleted in tandem for all the years without vouching key evidences & merits of the cases but by outdoing the provisions of rule 46A (supra) and section 250(6) of the Act. ITAT-Panaji Page 9 of 16 M/s Potdar Brothers ITA Nos.175 to 177 & 179 to 180/PAN/2025

Assistant Commissioner of Income Tax, Central Circle, Belagavi vs. M/S Potdar Brothers, Belagavi

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

ITA 179/PAN/2025[2021-22]Status: DisposedITAT Panaji18 Nov 2025AY 2021-22

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]
Section 132Section 133ASection 138Section 143(1)Section 143(3)Section 147Section 148Section 246ASection 250Section 253(2)

course of hearing, the Ld. DR at the very outset has commonly alleged that; the impugned orders not only suffered from compliance of rule 46A of Income Tax Rules, 1962 [‘IT- Rules’ hereinafter] but transgressed the provisions of s/s (1) of section 251 and s/s (6) of section ... these additions were deleted in tandem for all the years without vouching key evidences & merits of the cases but by outdoing the provisions of rule 46A (supra) and section 250(6) of the Act. ITAT-Panaji Page 9 of 16 M/s Potdar Brothers ITA Nos.175 to 177 & 179 to 180/PAN/2025

Assistant Commissioner of Income Tax, Central Circle, Belagavi vs. M/S Potdar Brothers, Belagavi

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

ITA 177/PAN/2025[2020-21]Status: DisposedITAT Panaji18 Nov 2025AY 2020-21

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]
Section 132Section 133ASection 138Section 143(1)Section 143(3)Section 147Section 148Section 246ASection 250Section 253(2)

course of hearing, the Ld. DR at the very outset has commonly alleged that; the impugned orders not only suffered from compliance of rule 46A of Income Tax Rules, 1962 [‘IT- Rules’ hereinafter] but transgressed the provisions of s/s (1) of section 251 and s/s (6) of section ... these additions were deleted in tandem for all the years without vouching key evidences & merits of the cases but by outdoing the provisions of rule 46A (supra) and section 250(6) of the Act. ITAT-Panaji Page 9 of 16 M/s Potdar Brothers ITA Nos.175 to 177 & 179 to 180/PAN/2025

Assistant Commissioner of Income Tax, Central Circle, Belagavi vs. M/S Potdar Brothers, Belagavi

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

ITA 176/PAN/2025[2019-20]Status: DisposedITAT Panaji18 Nov 2025AY 2019-20

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]
Section 132Section 133ASection 138Section 143(1)Section 143(3)Section 147Section 148Section 246ASection 250Section 253(2)

course of hearing, the Ld. DR at the very outset has commonly alleged that; the impugned orders not only suffered from compliance of rule 46A of Income Tax Rules, 1962 [‘IT- Rules’ hereinafter] but transgressed the provisions of s/s (1) of section 251 and s/s (6) of section ... these additions were deleted in tandem for all the years without vouching key evidences & merits of the cases but by outdoing the provisions of rule 46A (supra) and section 250(6) of the Act. ITAT-Panaji Page 9 of 16 M/s Potdar Brothers ITA Nos.175 to 177 & 179 to 180/PAN/2025

Assistant Commissioner of Income Tax, Central Circle, Belagavi vs. M/S Potdar Brothers, Belagavi

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

ITA 175/PAN/2025[2018-19]Status: DisposedITAT Panaji18 Nov 2025AY 2018-19

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]
Section 132Section 133ASection 138Section 143(1)Section 143(3)Section 147Section 148Section 246ASection 250Section 253(2)

course of hearing, the Ld. DR at the very outset has commonly alleged that; the impugned orders not only suffered from compliance of rule 46A of Income Tax Rules, 1962 [‘IT- Rules’ hereinafter] but transgressed the provisions of s/s (1) of section 251 and s/s (6) of section ... these additions were deleted in tandem for all the years without vouching key evidences & merits of the cases but by outdoing the provisions of rule 46A (supra) and section 250(6) of the Act. ITAT-Panaji Page 9 of 16 M/s Potdar Brothers ITA Nos.175 to 177 & 179 to 180/PAN/2025

Assistant Commissioner of Income Tax, Ghaziabad vs. Jaspal Singh Saluja, Ghaziabad

Accordingly, the appeal of Revenue is dismissed in the above terms

ITA 3979/DEL/2025[2018-19]Status: DisposedITAT Delhi18 Nov 2025AY 2018-19

Bench: Shri Mahavir Singh & Shri Manish Agarwalasstt. Year: 2018-19 Acit Vs Shri Jaspal Singh Saluja 201-202, 2Nd Floor, R-7/21, New Raj Nagar, Cgo-1 Near Purani Hapur Ghaziabad- 201001 Chungi, Kamala Nehru Nagar, Uttar Pradesh Ghaziabad (Appellant) (Respondent) Pan No. Agpss0863Q

For Appellant: Shri R.S Ahuja, CAFor Respondent: Dr. Rajinder Kaur, CIT DR
Section 143(3)Section 144BSection 68

many opportunities spanning a period of 6 months. Thus, the Ld. CIT(A) has not acted in consonance with the provisions of Income Tax Rule 46A while deciding the case. ” 3. Brief facts of the case are that the Assessee is engaged in the business of trading in electronic items

Deputy Commissioner of Income Tax-(1), Raipur vs. Goenka Rockwool India Private Limited, Raipur

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

ITA 453/RPR/2025[2013-14]Status: DisposedITAT Raipur17 Nov 2025AY 2013-14

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.453/Rpr/2025 Co No. 18/Rpr/2025 "नधा"रण वष" / Assessment Year : 2013-14 The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.)

For Appellant: Shri R.B Doshi, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 143(3)Section 147Section 250

been vehemently contended by the Ld. Sr. DR that while giving relief to the assessee, the Ld. CIT(Appeals)/NFAC had not complied with Rule 46A(3) of the ITAT Rules, 1962 while adjudicating on various evidence and till date, there is no remand report called for and the entire ... during the assessment proceedings. The appellant submitted that it was prevented by sufficient cause from producing the evidence before the AO in terms of Rule 46A(1)(c). Therefore, the same was forwarded to the AO for a remand report vide letter dated 13.06.2024. further reminders were sent