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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

Income Tax Officer, Ward-3(1)(1), Ahmedabad. vs. Neptune Overseas Ltd., Ashram Road

In the result, the appeal of the Department is dismissed

ITA 253/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad10 Jun 2025AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Ashok Kumar Suthar, Sr. D.RFor Respondent: Shri Hardik Vora, A.R
Section 148Section 40Section 68

prejudice to the above, the Ld. CIT(A), looking into the facts of the assessee’s case took on record substantial additional evidence under Rule 46A and sent the same to the AO for his review and called for a remand report. However, despite issuance of two reminders

Income Tax Officer, Balurghat vs. Debasish Das, Patiram

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

ITA 1235/KOL/2023[2018-19]Status: DisposedITAT Kolkata10 Jun 2025AY 2018-19

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Section 133(6)Section 139Section 144Section 148

erred by admitting fresh evidence without sending back the same to the AO while calling for remand report in contravention of Rule 46A(3) of the Rules. 5. Though there was none to appear on behalf of the assessee, but going over the order passed

Sarika Sajjan Agrawal, Mumbai vs. Income Tax Officer, Ward 42(1)(5), Mumbai

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

ITA 6638/MUM/2024[2012-13]Status: DisposedITAT Mumbai10 Jun 2025AY 2012-13

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraassessment Year: 2012-13 Mrs. Sarika Sajjan Agrawal, Income Tax Officer, 7/538, City End Chs Ltd., Ward 42(1)(5) Gorai Road, Vs. Room No.945, Borivali West, Kautilya Bhavan, Mumbai-400091. Bandra Kurla Complex, Pan: Aftpa1907Q Mumbai – 400051. (Appellant) (Respondent) Present For: Assessee By : Shri Lalchand Choudhary, Ld. C.A. Revenue By : Shri. Manoj Kumar Sinha, Ld.Sr.D.R. Date Of Hearing : 07.04.2025 Date Of Pronouncement : 10.06.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 01.11.2024, Impugned Herein, Passed By The National Faceless Appeal Center (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2012-13. 2. In This Case, An Information Was Received From Ddit (Investigation) Unit-8(2), Mumbai Dated 07.03.2019 To The Effect That During The Investigation Carried Out By The Income Tax Department, It Was Found That The Assessee During The Year Under Consideration Has Made Transaction Of Rs.27,73,881/- In A Penny Stock-M/S. Tilak Ventures Ltd., Which Has Been Used To Facilitate Introduction Of Unaccounted Income Of The Members Of The 2 Mrs. Sarika Sajjan Agrawal Beneficiaries In The Form Of Exempt Long Term Capital Gain/Short Term Capital Loss, In Their Books Of Account.

For Appellant: Shri Lalchand Choudhary, Ld. C.AFor Respondent: Shri. Manoj Kumar Sinha, Ld.Sr.D.R
Section 131Section 133(6)Section 144Section 147Section 148Section 250

appeal before the Ld. Commissioner and during the appellate proceedings before the Ld. Commissioner, uploaded certain fresh evidences but without making any application under rule 46A of the Income Tax Rules, 1962 (in short ‘the Rules’) as alleged in the impugned order and therefore the Ld. Commissioner without admitting

ACIT, C.C.-1, Jsr vs. M/S Jamshedpur Urban Co-Operative Bank Ltd., Jsr

In the result, appeal of the revenue stands partly allowed

ITA 42/RAN/2020[2017-18]Status: DisposedITAT Ranchi09 Jun 2025AY 2017-18

Bench: BEFORES/SHRI GEORGE MATHAN, JUDICIAL MEMBER AND RATNESH NANDAN SAHAY (Accountant Member)

For Appellant: ShriSharwan Kumar Jha, ARFor Respondent: Smt. Rinku Singh, CIT DR

rival submissions. A perusal of the grounds raised by the revenue clearly shows that the revenue has raised the issue of violation of Rule 46A. A perusal of the assessment order also clearly shows that the assessee has not cooperated in the course of assessment proceedings. A perusal ... 08/Ran/2020 Assessment Year: 2017-18 produced by the assessee before the ld CIT(A), The ld CIT(A) has not considered the provisions of Rule 46A and has admitted the additional evidences without giving any reason. Ld CIT(A) has considered such additional evidences and has deleted the addition. Here

Chanchalben Dahyabhai Patel, Daman vs. Income Tax Officer, Daman

ITA 1037/SRT/2024[2014-15]Status: DisposedITAT Surat09 Jun 2025AY 2014-15

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1035-1038/Srt/2024 (Ays: 2011-12, 2013-14, 2014-15 & 2015-16) (Hybrid Hearing) Chanchalben Dahyabhai Patel Income Tax Officer, Ward-Daman, 40, A.Dabhel Ghelwad Faila, बनाम / Jeevanji Hotel Building, Kathiria, Nani, Daman-396 210 Vs. Devka Road, Nani Daman-396 210 स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aljpp 3816 D (अपीलार्थी/Appellant) (प्रत्यर्थी / Respondent) निर्धारिती की ओर से /Appellant By Shri Chandra Jha, Ar राजस्व की ओर से /Respondent By Shri Ravi Kant Gupta, Cit-Dr सुनवाई की तारीख/Date Of Hearing 26/03/2025 उद्घोषणा की तारीख/Date Of Pronouncement | 09/06/2025 आदेश / Order Per Bijayananda Pruseth, Am: These Four Appeals By The Assessee Emanate From Separate Orders Passed Under Section 250 Of The Income-Tax Act, 1961 (In Short, 'The Act') By The National Faceless Appeal Centre, Delhi/Commissioner Of Income-Tax (Appeals) [In Short, “Nfac/Cit(E)”] All Dated 13.08.2024, For The Assessment Years (Ay) 2011-12, 2013-14, 2014-15 & 2015-16, Which In Turn Arose Out Of Assessment Orders Passed By Assessing Officer (In Short, ‘Ao') U/S 147 R.W.S. 144 R.W.S.144B Of The Act On 26.12.2018, 25.03.2022 & 28.03.2022 Respectively. In All The Appeals, The Facts Are Common & Grounds Of Appeals Raised By The Assessee Are Similar Except Variance Of Amounts. Hence, With The Consent Of The Parties, All The Appeals Were Clubbed & Heard Together & Are Decided By This Consolidated Order For Sake Of Convenience & Brevity.

Section 147Section 250

IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER & SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER

Chanchalben Dahyabhai Patel, Daman vs. Income Tax Officer, Daman

ITA 1035/SRT/2024[2011-2012]Status: DisposedITAT Surat09 Jun 2025AY 2011-2012

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1035-1038/Srt/2024 (Ays: 2011-12, 2013-14, 2014-15 & 2015-16) (Hybrid Hearing) Chanchalben Dahyabhai Patel Income Tax Officer, Ward-Daman, 40, A.Dabhel Ghelwad Faila, Vs. Jeevanji Hotel Building, Kathiria, Nani, Daman-396 210 Devka Road, Nani Daman-396 210 स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aljpp 3816 D (अपीलार्थी/Appellant) (प्रत्यर्थी / Respondent) निर्धारिती की ओर से /Appellant By Shri Chandra Jha, Ar राजस्व की ओर से /Respondent By Shri Ravi Kant Gupta, Cit-Dr सुनवाई की तारीख/Date Of Hearing 26/03/2025 उद्घोषणा की तारीख/Date Of Pronouncement | 09/06/2025 आदेश / Order Per Bijayananda Pruseth, Am: These Four Appeals By The Assessee Emanate From Separate Orders Passed Under Section 250 Of The Income-Tax Act, 1961 (In Short, 'The Act') By The National Faceless Appeal Centre, Delhi/Commissioner Of Income-Tax (Appeals) [In Short, “Nfac/Cit(E)”] All Dated 13.08.2024, For The Assessment Years (Ay) 2011-12, 2013-14, 2014-15 & 2015-16, Which In Turn Arose Out Of Assessment Orders Passed By Assessing Officer (In Short, ‘Ao') U/S 147 R.W.S. 144 R.W.S.144B Of The Act On 26.12.2018, 25.03.2022 & 28.03.2022 Respectively. In All The Appeals, The Facts Are Common & Grounds Of Appeals Raised By The Assessee Are Similar Except Variance Of Amounts. Hence, With The Consent Of The Parties, All The Appeals Were Clubbed & Heard Together & Are Decided By This Consolidated Order For Sake Of Convenience & Brevity.

Section 147Section 250

IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER & SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER

Eastman International, Ludhiana vs. Deputy Commissioner of Income Tax, Circle-1, Ludhiana

In the result, appeal of the Assessee is allowed

ITA 782/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh09 Jun 2025AY 2020-21

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashwani Kumar &For Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 115JSection 143(3)Section 250Section 41(1)Section 68Section 80I

produced before the Learned Assessing Officer. Thus, these are the additional evidences for which no application for admitting additional evidence as required by the Rule 46A of Income Tax Rules, 1962, has been filed. Thereby the additions made in the assessment were upheld by him. The submissions of the assessee ... assessee that would warrant an addition under Section 68. The Ld. CIT(A) erred in dismissing the reconciliations as additional evidence under Rule 46A of the Income Tax Rules, 1962, without appreciating that similar details were submitted before the AO in response to the show-cause notice. The addition under

Triveni Knits Private Limited, Ludhiana vs. ITO Ward 1 (3), Ludhiana

ITA 246/CHANDI/2024[2013-14]Status: DisposedITAT Chandigarh09 Jun 2025AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Rajesh Mehru, CA and Shri Dev Mehru, CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 56(2)(vib)Section 56(2)(viib)Section 69

partners in the firm, and in the same ratio. 7. During the appellate proceedings before the CIT(A), the assessee filed additional evidence under Rule 46A of the Income Tax Rules, including a valuation report prepared under the Discounted Cash Flow (DCF) method by 3 a Chartered Accountant ... based NAV method may not reflect the true value. Ld. CIT(A) called for the remand report from Assessing Officer. 8. In accordance with Rule 46A(3), the additional evidence was forwarded to the AO for examination. The AO submitted a remand report objecting to both the admissibility

Jaiambay Commercial Pvt. Ltd., Kolkata vs. I.T.O., Ward - 60(2), Kolkata

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

ITA 2623/KOL/2024[2012-2013]Status: DisposedITAT Kolkata09 Jun 2025AY 2012-2013

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 143(3)Section 249(2)Section 250

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, if required. Accordingly, the grounds taken by the assessee in his appeal are allowed

Anand Agrawal, Bhopal vs. Income Tax Officer 1 Harda, Harda

Appeal of the assessee is allowed for statistical

ITA 793/IND/2024[2012-13]Status: DisposedITAT Indore06 Jun 2025AY 2012-13

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshianand Agrawal, Income Tax Officer-1, बनाम/ A-104, Siddharth Lake Harda Vs. City, Raisen Road, Anand Nagar, Bhopal

Section 144Section 246ASection 250Section 253Section 69

erred in sustaining the addition made u/s 69 of Rs. 10,61,200 without admitting the additional evidences filed under rule 46A of the Income Tax Rules which go to the root of the matter. 5. On the facts and circumstances of the case and applicable ... contended that “impugned assessment order” is u/s 144 of the Act. Further Ld. CIT(A) has dismissed additional evidence application of the assessee under Rule 46A of the Act. Hence there is no meritorious disposal of case and it would be just and fair that the matter be remanded back

Assistant Commissioner of Income Tax Corporate Circle 1 1, Chennai vs. Hitachi Solutions India Private Limited, Kanchipuram

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

ITA 1715/CHNY/2024[2018-19]Status: DisposedITAT Chennai06 Jun 2025AY 2018-19

Bench: SHRI GEORGE GEORGE K, VICE PRESIDENT AND\nSHRI S.R. RAGHUNATHA, ACCOUNTANT MEMBER\nआयकर अपीलसं./IT(TP)A No.: 17/CHNY/2024\nनिर्धारण वर्ष / Assessment Year: 2018-19\nHitachi Solutions India Private\nLimited,\nBlock 5, 10th Floor, 1/124,\nDLF IT Park, Shivaji Gardens,\nMount Poonamallee Road,\nChennai - 600 089.\nThe Deputy Commissioner of\nIncome Tax,\nVs. Corporate Circle- 1(1),\nNo.121, M.G.Road,\nChennai - 600 034.\n[PAN:AAACZ-1544-R]\n(अपीलार्थी/Appellant)\n(प्रत्यर्थी/Respondent)\nआयकर

For Appellant: Shri Darpan Kirpalani, Advocate by VirtualFor Respondent: Shri A. Sasikumar, C.I.T
Section 143(3)Section 153Section 153(1)Section 153(4)

case, in our considered view, the assessee has not furnished any additional evidence before the Id.CIT(A) and hence there is no violation of Rule 46A of the IT Rules. Hence, the grounds taken by the revenue are dismissed. 46. In the result, the appeal filed by the assessee

ACIT, New Delhi vs. Phoola Rani Chadha, New Delhi

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

ITA 3480/DEL/2024[2017-18]Status: DisposedITAT Delhi06 Jun 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Royphoola Rani Chadha Vs. Acit, Circle 30(1) Plot No. 23, Civic Centre, Road No. D-4 Dlf, Minto Road Phase-1, Dlf City New Delhi – 110002 Gurgaon, Haryana 122002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaapc1676L Appellant .. Respondent Acit, Vs. Phoola Rani Chadha Room No. 1001, 10Th C-51, Defence Colony Floor, E-2, Block, New Delhi – 110024 Civic Centre, Minto Road Delhi – 110002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaapc1676L Appellant .. Respondent

For Appellant: Sh. Ravi Bhatia, CAFor Respondent: Ms. Monika Singh, CIT, DR
Section 143(3)

without affording an opportunity to Revenue to examine the evidence submitted by assessee during course of appellate proceedings thereby violating provision of Rule 46A of IT Rules, when no evidences were submitted by the assessee during assessment proceedings. 3. That on facts and circumstances of the case ... unexplained investment without verifying the source of investment and also not calling for remand report from AO in this regard thereby violating provision of Rule 46A of IT Rules. 4. The appellant reserves right to add, alter or amend the grounds of appeal on or, before the date of disposal

Phoola Rani Chadha, New Delhi vs. Assistant Commissioner of Income Tax Circle 30(1), New Delhi

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

ITA 3469/DEL/2024[2017-18]Status: DisposedITAT Delhi06 Jun 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Royphoola Rani Chadha Vs. Acit, Circle 30(1) Plot No. 23, Civic Centre, Road No. D-4 Dlf, Minto Road Phase-1, Dlf City New Delhi – 110002 Gurgaon, Haryana 122002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaapc1676L Appellant .. Respondent Acit, Vs. Phoola Rani Chadha Room No. 1001, 10Th C-51, Defence Colony Floor, E-2, Block, New Delhi – 110024 Civic Centre, Minto Road Delhi – 110002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaapc1676L Appellant .. Respondent

For Appellant: Sh. Ravi Bhatia, CAFor Respondent: Ms. Monika Singh, CIT, DR
Section 143(3)

without affording an opportunity to Revenue to examine the evidence submitted by assessee during course of appellate proceedings thereby violating provision of Rule 46A of IT Rules, when no evidences were submitted by the assessee during assessment proceedings. 3. That on facts and circumstances of the case ... unexplained investment without verifying the source of investment and also not calling for remand report from AO in this regard thereby violating provision of Rule 46A of IT Rules. 4. The appellant reserves right to add, alter or amend the grounds of appeal on or, before the date of disposal

Bhupendra Sharma HUF, Noida vs. ITO Ward 5(1)(2(3), Noida

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

ITA 127/DEL/2024[2018-19]Status: DisposedITAT Delhi06 Jun 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Roybhupendra Sharma Huf Vs. Cit(A) Nfac E-9, Sector-41, Noida Delhi – 110001 Uttar Pradesh- 201301 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaghb3664P Appellant .. Respondent

For Appellant: Sh. Raghav Sharma, CA, &For Respondent: Ms. Harpreet Kaur Hansra, Sr
Section 143(3)Section 263

assessee would have provided evidences to support its claim. The Assessee further claimed to CIT(A) that it would place additional evidences under Rule 46A but has not submitted any details for two years because of which the CIT(A) was constrained to pass an ex- parte order

R.H. Agro Overseas (P) Ltd, New Delhi vs. ACIT, Circle-21(2), New Delhi

The appeal of the revenue is dismissed being devoid of any merit and bereft of any reasoning

ITA 1151/DEL/2021[2014-15]Status: DisposedITAT Delhi06 Jun 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Royr.H. Agro Overseas (P) Vs. Acit, Circle -21(2) Limited, A-7, 1St Floor, R. No. 222, C.R Bldg. South Exntension, New Delhi – 110002 Part-H, New Delhi – 110049 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadcr1069G Appellant .. Respondent Acit, Circle-20(2) Vs. M/S R.H. Agro Overseas New Delhi Pvt.Ltd. A-7, 1St Floor, South Extn. Part-Ii New Delhi- 110049 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadcr1069G Appellant .. Respondent

For Appellant: Sh. Raj Kumar Gupta, CAFor Respondent: Ms. Monika Singh, CIT, DR
Section 143(3)Section 145

that the appellant was not been able to produce documents/books of accounts during assessment proceedings. During appeal proceedings, the appellant filed additional evidence under Rule 46A which were remanded to the Assessing Officer. It is seen from the remand report that assessee has not submitted any details to enable

ACIT, Circle-20(2), New Delhi vs. R.H. Agro Overseas (P) Ltd., New Delhi

The appeal of the revenue is dismissed being devoid of any merit and bereft of any reasoning

ITA 4964/DEL/2018[2013-14]Status: DisposedITAT Delhi06 Jun 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Royr.H. Agro Overseas (P) Vs. Acit, Circle -21(2) Limited, A-7, 1St Floor, R. No. 222, C.R Bldg. South Exntension, New Delhi – 110002 Part-H, New Delhi – 110049 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadcr1069G Appellant .. Respondent Acit, Circle-20(2) Vs. M/S R.H. Agro Overseas New Delhi Pvt.Ltd. A-7, 1St Floor, South Extn. Part-Ii New Delhi- 110049 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadcr1069G Appellant .. Respondent

For Appellant: Sh. Raj Kumar Gupta, CAFor Respondent: Ms. Monika Singh, CIT, DR
Section 143(3)Section 145

that the appellant was not been able to produce documents/books of accounts during assessment proceedings. During appeal proceedings, the appellant filed additional evidence under Rule 46A which were remanded to the Assessing Officer. It is seen from the remand report that assessee has not submitted any details to enable

Deputy Commissioner of Income Tax-1(1), Raipur vs. Shree Kumar Singh Bhadoriya, Dantewada

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

ITA 154/RPR/2025[2017-18]Status: DisposedITAT Raipur05 Jun 2025AY 2017-18

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.154/Rpr/2025 "नधा"रण वष" / Assessment Year : 2017-18 The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.)

For Appellant: NoneFor Respondent: Shri S.L Anuragi, CIT-DR
Section 143(2)Section 143(3)Section 68

appellant submitted certificates obtained from Canara bank regarding the cash deposits made during the year under consideration as additional evidence to be admitted under Rule 46A of Income Tax Rules. 1962 (the Rules). 4 DCIT-1(1), Raipur Vs. Shree Kumar Singh Bhadoriya 6.2.3 The additional evidence submitted ... appellant was forwarded to the AO to file his objections to its admission under Rule 46A of the Rules. The AO vide his report dated 07.11.2024 submitted that the additional evidence shall not be admitted as the appellant's case does not fall under the exceptions enumerated in Sub Rule

Subhas Hansaraj Nandu, Bhachau, Kutch vs. National Faceless Assessment Centre, Delhi

In the result, appeal filed by the assessee is allowed

ITA 9/RJT/2024[2010-11]Status: DisposedITAT Rajkot05 Jun 2025AY 2010-11

Bench: Dr. Arjun Lal Saini(Hybrid Hearing) Assessment Year: (2010-11) Subhas Hansaraj Nandu Vs. National Faceless Assessment Opp:Shambhu Maharaj Bungalow Centre, Delhi. Bhachau, Gujarat. Pan : Afrpn 0720 J (Assessee) (Respondent) "नधा"रती क" ओर से/Assessee By : Shri Kalpesh Doshi, Ld. Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr.Dr

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr.DR
Section 142(1)Section 143(2)Section 143(3)Section 271(1)(c)Section 274Section 68

assessee and furnished before the Ld. CIT(A), during the appellate proceedings, along with an application for admission of additional evidence under Rule 46A of the Rules, wherein it was stated that the assessee was unable to provide details with respect to only 4 parties, as it was difficult

Bible Fellowship Centre, Pune vs. ITO (Exemption) Ward 1(2), Pune

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

ITA 995/PUN/2025[2025-26]Status: DisposedITAT Pune05 Jun 2025AY 2025-26

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.995/Pun/2025 िनधा"रण वष" / Assessment Year: 2015-16 Bible Fellowship Centre, V The Income Tax Officer, A-202, Lunkad Heritage, S Exemption Ward-1(2), Viman Nagar, Pune – 411014. Pune. Maharashtra. Pan: Aaatb8528J Appellant/ Assessee Respondent / Revenue Assessee By Ms.Kimaya Kudva – Ar (Virtual) Revenue By Smt. Sonal L Sonkavde –Addl.Cit(Dr) Date Of Hearing 05/06/2025 Date Of Pronouncement 05/06/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Addl.Cit(A)/[Nfac] Passed Under Section 250 Of The Act, For The A.Y.2015-16, Dated 25.03.2025 Emanating From Assessment Order U/S.143(3) Of The Act, Dated 29.12.2017. Findings & Analysis : 2. We Have Heard Both The Parties & Perused The Records. In This Case, Assessee Is A Trust, But Assessee Trust Is Not Registered

Section 11Section 12ASection 143(3)Section 250

case, there was sufficient cause which prevented Assessee from filing the necessary documents, therefore, ld.CIT(A) should have admitted the additional evidence under Rule 46A of the Income Tax Rules, 1963. In these facts and circumstances of the case, we set-aside the order of ld.CIT(A) to ld.CIT

Assistant Commissioner of Income Tax, Central Circle-1, Trichy vs. Kumarasamy Ramakrishnan, Karur

In the result, all the three appeals filed by the Revenue are dismissed

ITA 3321/CHNY/2024[2018-19]Status: DisposedITAT Chennai05 Jun 2025AY 2018-19

Bench: Shri Duvvuru Rl Reddy & Shri S. R. Raghunathaआयकर अपीलसं/.Ita Nos.:3315, 3316 & 3321/Chny/2024 िनधा"रण वष" / Assessment Years: 2019-20, 2020-21 & 2018-19

For Appellant: Shri A. Sasikumar, CITFor Respondent: Shri.M.V.Prasad, C.A.&
Section 3Section 801ASection 801A(3)(ii)Section 80I

mandatory condition prescribed in section 80IA(3)(ii). We find that during the course of the appellate proceedings, the assessee submitted additional evidence under Rule 46A of I.T Rules before the ld.CIT(A) in order to substantiate the factual claims made in the grounds of appeal that the wind mill