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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 Circle-1, Dhanbad vs. Sri Vikash Agarwal, Dhanbad

In the result, grounds of appeal raised by the revenue is allowed for statistical purposes

ITA 133/RAN/2023[2018-19]Status: DisposedITAT Ranchi30 Jul 2025AY 2018-19

Bench: Shri Duvvuru Rl Reddy & Shri Ratnesh Nandan Sahay

Section 133(6)

being explainable, which have been furnished for the first time during appellate proceedings, which amounts to a clear violation of the mandate of the Rule 46A of the Income Tax Rules. (ii) Whether the Ld.CIT(A) has erred in law and in facts in relying on fresh evidences /arguments during ... appellate proceedings without seeking the remand/comments of the AO, which is a clear violation of rule 46A of the Income Tax Rules. (iii) Whether the Ld.CIT(A) has erred in law and in facts while considering the Amounts

Deputy Commissioner of Income Tax-1(1), Raipur vs. C. G. Ispat Private Limited, Raipur

ITA 95/RPR/2025[2014-15]Status: DisposedITAT Raipur30 Jul 2025AY 2014-15

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 95/Rpr/2025 (िनधा"रण वष" Assessment Year: 2014-15)

For Appellant: Shri R. B. Doshi, CAFor Respondent: Shri S. L. Anuragi, CIT-DR
Section 143(3)Section 147Section 250Section 92BSection 92C

addition made by the AO to the tune of Rs. 6,16,68,732/- by admitting additional evidences in contravention of Income Tax Rules 46A and there by ignoring the facts brought on the record by the AO. 3. Whether on the facts and in the circumstance of the case ... that Ld. CIT(A) has admitted additional evidence during the appellate proceedings before him while contemplating upon the issue in contravention of provisions of Rule 46A of the Income Tax Rules. With such submission, it was the prayer by Ld. CIT-DR that the order passed

Shobhana Dinesh Trivedi, Valsad vs. ACIT, Vapi Circle, Vapi

In the result, the appeal filed by the Assessee is allowed for statistical purpose

ITA 1042/SRT/2024[2016-17]Status: DisposedITAT Surat30 Jul 2025AY 2016-17

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Bijayananda Pruseth (Accountant Member)

Section 143(3)Section 45(1)Section 54

observing as follows: “8.1. I also find that the assessee did not 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

Ap Rajiv Swagruha Corporation Limited, Vijayawada vs. DCIT., Circle-1(1), Hyderabad

ITA 756/HYD/2025[2017-18]Status: DisposedITAT Hyderabad30 Jul 2025AY 2017-18

Bench: Us:

Section 143(2)Section 143(3)Section 250Section 40Section 43B

course of the appellate proceedings before the CIT(A), the assessee company filed an application seeking admission of certain documents as “additional evidence” under Rule 46A of the Income Tax Rules, 1962. On a perusal of the record, we find that the assessee company had sought for admission ... following documents as additional evidence in its application filed under Rule 46A of the Income Tax Rules, 1962 : 1. Ledger extract of Service Tax Liability. 2. R.A. Bills. 3. Financials of the Assessee. 6. The assessee company in its application while seeking liberty for admission of additional evidence, had submitted

Assistant Commissioner of Income Tax, Madurai vs. S. Rajendran, Chitharal

ITA 2904/CHNY/2024[2020-21]Status: DisposedITAT Chennai30 Jul 2025AY 2020-21

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:2903 & 2904/Chny/2024 निर्धारण वर्ष / Assessment Years: 2015-16 & 2020-21 The Assistant Commissioner Of Income Tax, Central Circle -2, Madurai. (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement S.Rajendran, Vs.13-85/42A, Parthittavillai Veedu, Chitharal Pο, Kanyakumari District, Nagercoil – 629 151. [Pan:Afqpr-2835-H] (प्रत्यर्थी/Respondent) Shri. M. Murali, C.I.T. & Shri. Kumar Chandan, J.C.I.T. Shri. T. Vasudevan, Advocate 20.06.2025 30.07.2025 आदेश /Order Per S. R. Raghunatha: These Appeals Filed By The Revenue Are Directed Against The Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Years 2015-16 & 2020-21, Vide Order Dated 19.09.2024 Respectively. Since Facts Are Identical & Issues Are Common, Appeals Filed By The Revenue Were Heard & Are Being Disposed Of By This Consolidated Order.

Section 68

list of creditors and the credit balances of KKM Blue Metals & KKM Bricks Unit without giving opportunity to the Assessing Officer under Rule 46A of the I.T.Rules mandated. 4. The CIT(A) has erred in deleting the addition of disallowance of the Depreciation claimed of Rs.1 ... calling for a remand report as mandated under Rule 46A of the Act on the submission of the assessee as the AO categorically in his order stated that no details were furnished during assessment proceedings. No opportunity was given to the AO to examine and vouch for the veracity

Assistant Commissioner of Income Tax, Madurai vs. S.Rajendran, Chitharal Po

ITA 2903/CHNY/2024[2015-16]Status: DisposedITAT Chennai30 Jul 2025AY 2015-16

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:2903 & 2904/Chny/2024 निर्धारण वर्ष / Assessment Years: 2015-16 & 2020-21 The Assistant Commissioner Of Income Tax, Central Circle -2, Madurai. (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement : : S.Rajendran, Vs.13-85/42A, Parthittavillai Veedu, Chitharal Pο, Kanyakumari District, Nagercoil – 629 151. [Pan:Afqpr-2835-H] (प्रत्यर्थी/Respondent) Shri. M. Murali, C.I.T. & Shri. Kumar Chandan, J.C.I.T. Shri. T. Vasudevan, Advocate 20.06.2025 30.07.2025 आदेश /Order Per S. R. Raghunatha: These Appeals Filed By The Revenue Are Directed Against The Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Years 2015-16 & 2020-21, Vide Order Dated 19.09.2024 Respectively. Since Facts Are Identical & Issues Are Common, Appeals Filed By The Revenue Were Heard & Are Being Disposed Of By This Consolidated Order. :-2-:

Section 68

list of creditors and the credit balances of KKM Blue Metals & KKM Bricks Unit without giving opportunity to the Assessing Officer under Rule 46A of the I.T.Rules mandated. 4. The CIT(A) has erred in deleting the addition of disallowance of the Depreciation claimed of Rs.1 ... calling for a remand report as mandated under Rule 46A of the Act on the submission of the assessee as the AO categorically in his order stated that no details were furnished during assessment proceedings. No opportunity was given to the AO to examine and vouch for the veracity

Satyajeet Gajendra Dali, Mumbai vs. Income Tax Officer-Ward 19(3)(1), Mumbai, Piramal Chamber

ITA 1582/MUM/2025[2010-11]Status: DisposedITAT Mumbai30 Jul 2025AY 2010-11

Bench: Shri Vikram Singh Yadav & Shri Sandeep Gosain

For Appellant: Shri Meet JimudiyaFor Respondent: Shri Swapnil Choudhary
Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “G” BENCH : MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI SANDEEP

Income Tax Officer Ward-16(3), Delhi ITO vs. Mansarover Exim Pvt. Ltd., Delhi

ITA 1275/DEL/2024[2012-13]Status: DisposedITAT Delhi30 Jul 2025AY 2012-13

Bench: Ms.Madhumita Roy & Shri Manish Agarwal[Assessment Year : 2012-13] Ito, Vs Mansarover Exim Pvt.Ltd., Ward-16(3), 2, First Floor, Pocket-H-34, Delhi Plot No.35, Sector-3, Rohini, New Delhi-110085. Pan-Aaecm9328A Appellant Respondent Revenue By Ms. Amisha S.Gupta, Cit Dr Assessee By Shri Rohit Jain, Adv., Shri Shourya Jain, Ca & Shri Deepesh Jain, Adv. Date Of Hearing 06.05.2025 Date Of Pronouncement 30.07.2025 Order

Section 131Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 250Section 68

onus as per requirement of sec 68 of the Act. The assessee carried the matter before ld. CIT(A) and filed additional evidence under rule 46A of the Rules on which remand report was called wherein the Assessing Officer did not made any adverse comment on the additional documentary evidence ... lender party before AO to prove identity, genuineness and creditworthiness of the party. During the course of appellate proceedings, appellant filed an application under Rule 46A and filed following documents to prove identity, genuineness and creditworthiness of the party: i. Copy of Acknowledgement of IT. Paper Book page

Prayag Capitals India Limited, Allahabad vs. ITO, Ward-2(2) Now Ward-2(1), Allahabad

In the result, the appeal of the assessee stands allowed

ITA 81/ALLD/2024[2015-16]Status: DisposedITAT Allahabad29 Jul 2025AY 2015-16

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(3)

notices issued during the assessment proceedings. Further he submitted that the learned CIT(A) had admitted additional evidence within the provisions of Rule 46A of the I.T. Rules in accordance with law, which are now part of record and should be given full consideration. He also submitted that the learned

Income Tax Officer, Silvassa vs. Ansuya Puspavijaysinh Parmar, Silvassa

In the result, all three appeals filed by the Revenue as well as all the three cross objections filed by the assessee are dismissed

ITA 771/SRT/2024[2017-18]Status: DisposedITAT Surat29 Jul 2025AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Bijayananda Pruseth Ita Nos. 769 To 771/Srt/2024 Assessment Year 2015-16 To 2017-18

For Appellant: Shri Rajan Upadhyay, A.RFor Respondent: Shri Ajay Uke, Sr. D.R
Section 251(1)Section 43BSection 46A

additional evidence u/s 46A and allowing the assessee's appeal without getting them verified from the AO in violation of the provisions of rule 46A(3) of the Income Tax Rules, 1962. 1.2 On the facts and circumstances of the case, the ld. CIT(A) erred in not enhancing ... additional evidence u/s 46A and allowing the assessee's appeal without getting them verified from the AO in violation of the provisions of rule 46A(3) of the Income Tax Rules, 1962. 1.2 On the facts and circumstances of the case, the ld CIT(A) erred in not enhancing

Income Tax Officer, Silvassa vs. Ansuya Pushpvijaysinh Parmar, Silvassa

In the result, all three appeals filed by the Revenue as well as all the three cross objections filed by the assessee are dismissed

ITA 770/SRT/2024[2016-17]Status: DisposedITAT Surat29 Jul 2025AY 2016-17

Bench: Ms. Suchitra Kamble & Shri Bijayananda Pruseth Ita Nos. 769 To 771/Srt/2024 Assessment Year 2015-16 To 2017-18

For Appellant: Shri Rajan Upadhyay, A.RFor Respondent: Shri Ajay Uke, Sr. D.R
Section 251(1)Section 43BSection 46A

additional evidence u/s 46A and allowing the assessee's appeal without getting them verified from the AO in violation of the provisions of rule 46A(3) of the Income Tax Rules, 1962. 1.2 On the facts and circumstances of the case, the ld. CIT(A) erred in not enhancing ... additional evidence u/s 46A and allowing the assessee's appeal without getting them verified from the AO in violation of the provisions of rule 46A(3) of the Income Tax Rules, 1962. 1.2 On the facts and circumstances of the case, the ld CIT(A) erred in not enhancing

Income Tax Officer, Silvassa vs. Ansuya Pushpvijaysinh Parmar, Silvassa

In the result, all three appeals filed by the Revenue as well as all the three cross objections filed by the assessee are dismissed

ITA 769/SRT/2024[2015-16]Status: DisposedITAT Surat29 Jul 2025AY 2015-16

Bench: Ms. Suchitra Kamble & Shri Bijayananda Pruseth Ita Nos. 769 To 771/Srt/2024 Assessment Year 2015-16 To 2017-18

For Appellant: Shri Rajan Upadhyay, A.RFor Respondent: Shri Ajay Uke, Sr. D.R
Section 251(1)Section 43BSection 46A

additional evidence u/s 46A and allowing the assessee's appeal without getting them verified from the AO in violation of the provisions of rule 46A(3) of the Income Tax Rules, 1962. 1.2 On the facts and circumstances of the case, the ld. CIT(A) erred in not enhancing ... additional evidence u/s 46A and allowing the assessee's appeal without getting them verified from the AO in violation of the provisions of rule 46A(3) of the Income Tax Rules, 1962. 1.2 On the facts and circumstances of the case, the ld CIT(A) erred in not enhancing

Minesh Bipinbhai Patel, Vadodara vs. The Dy.CIT, Central Circle-1, Vadodara

In the result the appeal of the assessee for A

ITA 650/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad29 Jul 2025AY 2016-17

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarit(Ss)A No.23/Ahd/2024 Asstt.Year : 2015-16 & Asstt.Year 2016-17 Minesh Bipinbhai Patel The Dcit, Cent.Cir.1 10, Shantivan Society Vs. Race Course Sussen Tarsali Road Vadodara. Makarpura Vadodara 390 010. Pan : Acqpp 7756 G (Appellant) (Respondent) Assessee By : Shri Tushar Hemani, Sr.Advocate Revenue By : Shri Sher Singh, Cit-Dr & Shri Hargovind Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 24/07/2025 घोषणा की तारीख /Date Of Pronouncement: 29/07/2025 आदेश/O R D E R आदेश आदेश आदेश

For Appellant: Shri Tushar Hemani, Sr.AdvocateFor Respondent: Shri Sher Singh, CIT-DR and Shri Hargovind Singh, Sr.DR
Section 132Section 139(1)Section 143(3)Section 153ASection 250

following reasons: - The report was obtained one and a half years after the assessment, and the assessee failed to establish any sufficient cause under Rule 46A of the Act as to why such report could not be filed earlier. There was no refusal by AO to admit evidence ... when the assessee sought to explain the recorded expenditure based on contemporaneous civil rates and activity-wise cost estimation. Even if not admissible under Rule 46A, the CIT(A) could have considered the report as an indicative corroborative aid. Notably, the CIT(A) failed to conduct independent

ACIT, Circle-2, Pune vs. Bhikshu Granimart, Pune

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

ITA 1158/PUN/2024[2017-18]Status: DisposedITAT Pune29 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

For Appellant: S/Shri Nikhil S Pathak & P D KudvaFor Respondent: Shri Ramnath P Murkunde
Section 133(6)Section 142(1)Section 143(2)Section 270A

admitting and relying upon certain 'additional evidences' submitted through paper book furnished by the assessee in contravention of the provisions laid under Income-tax Rules 46A(1), 46A(2) and 46A(3) r.w.s. 251 of the Income-tax Act, 1961? 2) Whether in the facts and circumstances of the case ... assesse which were admitted at the back of the Assessing Officer. Since the Ld. CIT(A) / NFAC has violated the provisions of Rule 46A of IT Rules, 1962 r.w.s. 251 of the Act and has not called for a remand report from the Assessing Officer, therefore, the order

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

In the result, the appeal of the Revenue stand dismissed and the

ITA 836/CHNY/2025[2021-22]Status: DisposedITAT Chennai29 Jul 2025AY 2021-22

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr.Vikram VijayaraghavanFor Respondent: Mr.Shiva Srinivas, CIT
Section 132Section 139(1)Section 142(1)Section 143(2)Section 56(2)(x)Section 92C

said price, according to the assessee, could not be said to represent FMV. 7. The assessee also filed an application in terms of Rule 46A before the Ld. CIT(A), seeking consideration of the updated valuation report dated 09.12.2022, which was prepared on the basis of audited financial statements prepared

Prakash Bare, Bengaluru vs. DCIT Circle 2(2)(1), Koramangala, Bengaluru

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

ITA 1030/BANG/2025[2022-23]Status: DisposedITAT Bangalore29 Jul 2025AY 2022-23

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year :2020-21

For Appellant: Shri. B. N. Pattabhi, CAFor Respondent: Shri. R. Rajamanohar, JCIT(DR)(ITAT), Bangalore

issue by observing as under :-- 11.4.1 The assessing officer has raised objection to the admission of additional evidence on the ground that as per rule 46A, additional evidence may only be accepted if there were any exceptional circumstances which prevented the assessee from filing the evidence during course of assessment ... officer has submitted that as per the facts and circumstances of the case, the appellant does not fulfill any of the conditions specified in rule 46A as the assessee had been given enough opportunity of being heard and was not prevented by any sufficient cause to produce the evidence during

Income Tax Officer, Delhi vs. Rakhee Walech, Delhi

In the result, Appeal of the Revenue is partly allowed for

ITA 5987/DEL/2024[2017-18]Status: DisposedITAT Delhi29 Jul 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 5987/Del//Del/2024 (A.Y 2017-18) Income Tax Officer Vs Rakhee Walecha, Room No. 1210, E-2, Block, Civic 455, Mandakini Enclave, Centre, New Delhi Alaknanda, New Delhi Pan: Aaipw4418J Appellant Respondent Assessee By Sh. Anuj Tiwari, Ca Revenue By Sh. Ajay Kumar Arora, Sr. Dr Date Of Hearing 16/07/2025 Date Of Pronouncement 29/07/2025

Section 36(1)(ii)Section 68

examine and verify the additional evidences submitted by the assessee during course of appellate proceedings and rebut the same thereby violating provision of Rule 46A of the Income Tax Rules, 1962. Thus, sought for setting aside the impugned order of the Ld. CIT(A) . 5. Per contra, the Ld. Assessee ... considered those additional evidence and deleted the additions/disallowance. In our considered opinion, the approach of the Ld. CIT(A) is contrary to Rule 46A of the Income Tax Rules, 1962. When an application under Rule 46A of the Income Tax Rules, 1962 was filed, the Ld. CIT(A) ought

Praveen Kumar Bansal, Bhiwani vs. Income Tax Officer, Bhiwani

In the result, the Appeal of the Appellant is partly allowed for

ITA 3181/DEL/2024[2015-16]Status: DisposedITAT Delhi29 Jul 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 3181/Del/2024 (A.Y 2015-16) Praveen Kumar Bansal Vs Income Tax Officer Haryana School Street, Bichla Income Tax Department Bazar, Bhiwani, Haryana, Bhiwani, Haryana 127021 Pan: Abqpb7886C Appellant Respondent Assessee By Sh. Mahesh Kasera, Adv Revenue By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 29/07/2025 Date Of Pronouncement 29/07/2025

Section 144BSection 147

additions. The Assessee preferred an Appeal before the Ld. CIT(A), wherein the Assessee also filed an application for admission of additional evidence under Rule 46A of the Income Tax Rules. The said application for admission of additional evidence came to be dismissed and ultimately 2 Praveen Kumar Bansal ... submitted that during the assessmentproceedings the Assessee could not produce those documents, therefore, the Assessee filed an application for admission of additional evidence under Rule 46A of the Income Tax Rules before the Ld. CIT(A). However, the Ld. CIT(A) committed error in rejecting the application filed

Patidar Builer Private Ltd., Bhopal vs. Assessing Officer, Bhopal

Appeal is allowed partly

ITA 556/IND/2023[2010-11]Status: DisposedITAT Indore28 Jul 2025AY 2010-11

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 143(2)Section 143(3)Section 37Section 40A(3)Section 68

submission to CIT(A) on the same line as filed to the AO. Further, the assessee also filed an application under Rule 46A of Income-tax Rules, 1962 to CIT(A) for admission of additional evidences, copy of assessee’s application is filed at Page 58 of Paper-Book. However

Income Tax Officer, Ward-7(1), Pune vs. Hemant Bagareddy Motadoo, Pune

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

ITA 1897/PUN/2024[2013-14]Status: DisposedITAT Pune28 Jul 2025AY 2013-14

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2013-14

For Appellant: S/Shri B C Malakar & Yuvraj ChavanFor Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 201Section 40Section 40A(3)Section 68

NFAC in deleting the additions / disallowances made by the Assessing Officer by passing a very cryptic order and admitting additional evidences in violation of Rule 46A. 5 He submitted that the provisions of section 40(a)(ia) of the Act cannot apply to a part of the payment instead ... assessee on the other hand strongly relied on the order of the Ld. CIT(A) / NFAC. He submitted that there is no violation of Rule 46A of the Income Tax Rules, 1962 and the grounds raised by the Revenue are void ab initio since no additional evidence was furnished before