← All Phrases

“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

Gayatri Shiksha Nyas, Agra vs. ITO(Exemption), Agra

In the result, both appeals filed by the assessee are allowed for statistical purposes

ITA 513/AGR/2025[2016-2017]Status: DisposedITAT Agra16 Feb 2026AY 2016-2017

Bench: : Shri S. Rifaur Rahman

Section 10Section 11Section 11(1)(d)Section 143(1)Section 154

violation of the principles of natural justice. 5. That the learned CIT(A) erred in not admitting and considering additional evidences under Rule 46A, which were crucial to determine the true nature of voluntary contributions and to decide the matter on merits, failure to do so renders the order

Jitendra Kumar Agarwal HUF, Agra vs. DCIT, Circle - 2(1)(1), Agra

In the result, assessee’s appeal is allowed

ITA 454/AGR/2025[2017-18]Status: DisposedITAT Agra16 Feb 2026AY 2017-18

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 115BSection 143(1)Section 143(2)Section 143(3)Section 250Section 68

November 2016. 4. That having regard to facts & circumstances of the case the learned CIT(A) NFAC, upon the admission of additional evidences under Rule 46A of the I.T. Rules and during pendency of their examination by the Assessing Officer, evident from the notice issued to the appellant fixing

ACIT Central Circle-1 Raipur, Raipur vs. Maruti Clean Coal and Power Limited, Raipur

In the result, appeal of the Revenue in ITA No

ITA 558/RPR/2025[2016-17]Status: DisposedITAT Raipur16 Feb 2026AY 2016-17

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. /It(Ss)A No.19/Rpr/2025 Co No.19/Rpr/2025 "नधा"रण वष" / Assessment Year : 2014-15 The Assistant Commissioner Of Income Tax, Central Circle-1, Raipur (C.G.) ........अपीलाथ" / Appellant बनाम / V/S. Maruti Clean Coal & Power Limited 8Th Floor, Cbd Complex, Sector-21, Atal Nagar, Naya Raipur, Raipur-492 018 Pan: Aadcm4810C ……""यथ" / Respondent

For Appellant: S/shri Salil Kapoor &For Respondent: Shri Yogesh Kumar Sharma, CIT-DR

deciding the matter based on these without providing the A.O with a proper opportunity to examine the same, thereby violating the provisions of Rule 46A of the Income Tax Rules, ignoring that: (a) That the additional evidences admitted by the CIT(A) were not forwarded to the A.O and remand ... opportunity to rebut the claim of the assessee, which were lodged before the CIT(A) for the first time in terms of Rule 46A(3)? (b) Normally whenever a document is proposed to be used against the assessee, it is provided in advance and about seven days are given

Assistant Commissioner of Income Tax, Mumbai vs. Freightbridge Logistics Private Limited, Mumbai

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

ITA 7792/MUM/2025[2022-23]Status: DisposedITAT Mumbai16 Feb 2026AY 2022-23

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri Ajay R. Singh a/w Mr. Akshay PawarFor Respondent: Ms. Kavitha Kaushik (SR DR)
Section 133(6)Section 143(3)Section 250Section 44B

assessment proceeding, it is found that the assessee has submitted evidence on the issue. 6. It is submitted that the exceptions laid down in Rule 46A of the Income tax Rules, 1962 for production of additional evidence before the appellate authorities are not fulfilled by the assessee. The assessee ... that may have prevented him from filing the evidence during the assessment procedure. Thus, the assessee does not satisfy any conditions laid down in Rule 46A of the Income Tax Rules, 1962 and thus, the evidence should not be accepted as it is not any additional evidence in the first

Sarfarazkhan Sarvarkhan Pathan, Ahmedabad vs. ITO, Ward3(3)(5), Ahmedabad

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

ITA 2016/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad13 Feb 2026AY 2012-13

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri P D Shah, ARFor Respondent: Shri C Dharani Nath, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 68Section 69Section 69A

duly recorded in the books of account and that the additions resulted in double taxation. The assessee also sought admission of additional evidence under Rule 46A of the Income-tax Rules and challenged the levy of interest under sections 234A, 234B and 234C as well as initiation of penalty proceedings ... Appeals). The ground relating to double taxation was dismissed for want of any supporting explanation. The request for admission of additional evidence under Rule 46A was rejected as no such evidence was actually filed. The levy of interest was upheld by relying upon the judgment of the Hon’ble Supreme

Parul Nilesh Mehta, Mumbai vs. DCIT, Circle 19(1), Mumbai

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

ITA 7768/MUM/2025[2013-14]Status: DisposedITAT Mumbai13 Feb 2026AY 2013-14

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Shri Satish ModyFor Respondent: Shri Virabhadra Mahajan, Sr.DR
Section 147Section 69A

further submitted that the assessee has taken certain legal grounds of appeal and has also sought permission to file additional evidences under Rule 46A before the Ld.CIT(A). However, the same has also not been adjudicated upon besides the fact that there is no finding on the merits

JCIT(OSD)-14(1)(1), Mumbai vs. Kukreja Builders Pvt. Ltd., Mumbai

In the result, the revenue’s appeal is partly allowed in the above terms

ITA 2102/MUM/2025[2013-14]Status: DisposedITAT Mumbai13 Feb 2026AY 2013-14

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2013-14 Dcit – 14(1)(1), Mumbai M/S. Kukreja Builders Room No. 432, 4Th Floor, Pvt. Ltd. Aayakarbhavan, M.K. Road, 4 & 5Th Floor, Sai Mumbai - 400020 Commercial Building, Bks Vs. Devshi Marg., Govandi (E), Mumbai, Maharashtra– 400088 Pan: Aacck5040M (Appellant) (Respondent) Present For: Assessee By : Shri Ajay Singh & Shri Akshay Pawar, Ld. A.R. Revenue By : Shri Hemanshu Joshi, (Sr. D.R.) Date Of Hearing : 12.12.2025 Date Of Pronouncement : 13.02.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 25.01.2025, Impugned Herein, Passed By The National Faceless Appeal Centre (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. 2013-14. 2. In The Instant Case, The Assessee During The A.Y. Under Consideration Had Declared Its Total Income As Rs. 2,20,00,580/- By Filing Its Return Of Income, Which Was Initially Processed Under Section 143 Of The Act. 2 M/S. Kukreja Builders Pvt. Ltd.

For Appellant: Shri Ajay Singh & Shri AkshayFor Respondent: Shri Hemanshu Joshi, (SR. D.R.)
Section 131Section 133(6)Section 143Section 250Section 68

shall be admitted under Sub-rule (1), unless the Ld. Commissioner records, in writing the reasons for its admission. Further, sub-rule (4) of Rule 46A prescribes that nothing contained in this Rule shall affect the power of the Ld. Commissioner to direct the production of any document ... enable him to dispose of the appeal or for any substantial cause, and therefore the exclusion clause available under sub-rule (4) of Rule 46A, would not be applicable in the instant case. Whatsoever it may be, it is a fact that the Assessing Officer has more or less made

DCIT, Circle 52(1), New Delhi vs. Bhupinder Singh Bhalla, New Delhi

Appeal of the revenue is dismissed

ITA 2964/DEL/2023[2016-17]Status: DisposedITAT Delhi13 Feb 2026AY 2016-17

Bench: Shri Mahavir Singh, Vice Presdient (), Shri Vimal Kumar & Shri Brajesh Kumar Singh

For Respondent: Dr Rakesh Gupta, Adv. (Virtual) S/Shri
Section 142(1)Section 142(3)Section 143(1)Section 143(2)Section 143(3)Section 250Section 54B

appellant and added the same to his income vide order u/s 143(3) dated 31/12/2018. During the appellate stage, additional evidence under Rule 46A was filed by the appellant before my predecessor on 21/08/2019. The appellant has submitted the following additional evidences to support his contentions: 1. Copy of order ... through any inquiry has to be confronted to the assessee which were not done. Further, ample evidences have been adduced by the appellant under Rule 46A to prove that the lands purchased are agricultural. The A.O has not controverted the evidence hence adduced. It is also important to mention that

DCIT, Circle -1(1)(1), Ahmedabad vs. Awlencan Innovations India Limited, Ahmedabad

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

ITA 1950/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad12 Feb 2026AY 2022-23

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaassessment Years: 2022-23

Section 143(3)Section 250

fresh evidences filed before him. The order of the Ld. CIT(A) is thus found to be in contravention to provision of Rule 46A(3) of the Income-Tax Rules, and his order cannot be upheld for this reason. It is further found that the assessee had furnished details

Mkf International, Mumbai vs. DCIT Circle 17(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 7726/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Feb 2026AY 2018-19

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarmkf International Dcit Circle 17(1), 1903/1905, Aarus Wing, Kautilya Bhavan, Wallace Fortuna, Shivdas Vs. Bkc, Mumbai – Chapsi Marg, Opp-Fazlani 400 051 School, Chinchbunder Ho, Mumbai-400 009 Pan/Gir No. Abhfm5244N (Applicant) (Respondent) Assessee By Shri Dharmesh Shah A/W Ms. Mitali Parekh, Ld. Ars Revenue By Shri Umashankar Prasad, Ld. Dr Date Of Hearing 10.02.2026 Date Of Pronouncement 12.02.2026

Section 115BSection 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 270ASection 68

also noted that the remand report concurred with the Assessing Officer’s findings and additional evidences were rejected for violation of Rule 46A. 8. Aggrieved by the order of the CIT(A) the assessee is in appeal before us raising following grounds of appeal: 1. The Ld. CIT(A) NFAC

Sree Narayana Guru Cooperative Thrift and Credit Society Limited, Dwarka Delhi vs. ITO 43(6), New Delhi

ITA 5165/DEL/2025[2017-18]Status: DisposedITAT Delhi12 Feb 2026AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

For Appellant: Sh. KVSR Krishna, CAFor Respondent: Ms. Ankush Kalra, SR.DR
Section 142(1)Section 143(2)Section 147Section 148

NFAC, Delhi and filed detailed submissions which are reproduced from page 2 to 11 of the appellate order and also filed additional evidences under Rule 46A of the IT Rules. Accordingly, a remand report was called from the Assessing Officer vide letter dated 06.03.2024. In response Assessing Officer filed

Sree Narayana Guru Cooperative and Credit Society Limited, Dwarka Delhi vs. ITO 43(6), New Delhi

ITA 5164/DEL/2025[2012-13]Status: DisposedITAT Delhi12 Feb 2026AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

For Appellant: Sh. KVSR Krishna, CAFor Respondent: Ms. Ankush Kalra, SR.DR
Section 142(1)Section 143(2)Section 147Section 148

NFAC, Delhi and filed detailed submissions which are reproduced from page 2 to 11 of the appellate order and also filed additional evidences under Rule 46A of the IT Rules. Accordingly, a remand report was called from the Assessing Officer vide letter dated 06.03.2024. In response Assessing Officer filed

Sanchay Jain, New Delhi vs. DCIT, Central Circle-30, New Delhi

ITA 3832/DEL/2025[2020-21]Status: DisposedITAT Delhi12 Feb 2026AY 2020-21

Bench: Shri Mahavir Singh & Shri Krinwant Sahay

For Appellant: Sh. Shantanu Jain, Adv. & Sh. Gurpreet SinghFor Respondent: Shir Mahesh Kumar, CIT(DR)
Section 127Section 132ASection 139(1)Section 142(1)Section 143(2)Section 143(3)Section 69A

assessee has filed a paper Book containing copy of written submission field before the CIT(A) dated 6.7.2022; copy of application under Rule 46A filed before the CIT(A) dated 6.7.2022; copy of reply dated 11.9.2021 filed by the assessee before the AO alongwith the following enclsorues viz. copy ... were filed before the CIT(A) and except copy of written submission filed before the CIT(A) dated 6.7.2022 and copy of application under Rule 46A filed before the CIT(A) dated 6.7.2022 were filed before the before the AO. We find that in above cited cases

ACIT, Circle-7(1), Delhi vs. Eberspaecher Suetrak Bus Climate Control Systems India Private Limited, Delhi

Appeal is dismissed as premature

ITA 3665/DEL/2025[2014-15]Status: DisposedITAT Delhi12 Feb 2026AY 2014-15

Bench: Shri.Rifaur Rahman & Shri Vimal Kumar

Section 133(6)Section 142(1)Section 143(2)Section 144Section 68

response to this letter the assessing officer vide his report dated 22.06.2018has submitted that: “Now, the assessee has filed an application under rule 46A as additional evidences along with submissions during the appellate proceedings before your good self. After verification of details submitted by the assessee along with additional ... remand report dated 07.09.2018 has stated that the additional evidences submitted by the appellant should not be admitted in the light of provisions of Rule 46A of Income Tax Rule 1962. The relevant part of the remand report dated 07.09.2018 is reproduced as under: “During the course of assessment proceedings

ITO, Ward- 2(3)(4), Hapur vs. Shiva and Shiva, Hapur

In the result, the Revenue’s appeal as well as Assessee’s cross objection stand dismissed

ITA 1945/DEL/2025[2020-21]Status: DisposedITAT Delhi12 Feb 2026AY 2020-21

Bench: Shri Mahavir Singh & Shri Krinwant Sahayito, Ward 2(3)(4), Vs. Shiva & Shiva Hapur Near Sri Ram Mandir, 3-A, Surya Vihar, L.N. School Marg, Near Ambedkar Chowk, Garh Road, Hapur, Up Hapur (Pan: Adxfs1969A) (Appellant) (Respondent) C.O. No. 101/Del/2025 (Ita No. 1945/Del/2025) (Ay 2020-21) Shiva & Shiva Vs. Ito, Ward 2(3)(4), Near Sri Ram Mandir, Hapur, Up L.N. School Marg, Garh Road, Hapur (Pan: Adxfs1969A) (Appellant) (Respondent) Revenue By : Sh. Manish Gupta, Sr. Dr. Assessee By : Sh. Ayaan Singh, Adv.

For Appellant: Sh. Ayaan Singh, AdvFor Respondent: Sh. Manish Gupta, Sr. DR
Section 142(1)Section 143(2)Section 40A(3)Section 68

position to submit the necessary details/documents due to reasonable, valid and genuine reason. However, Assessee has already submitted Application under Rule 46A of the Act alongwith the Appeal before the Ld. CIT(A) with the request to grant permission to submit the additional evidences in respect offers the capital introduced ... additional evidences. The additional evidences filed by the assessee were forwarded to the jurisdictional AO for his comments and report thereon, in terms of Rule 46A of the Income Tax Rules. The AO has submitted his report on 01.01.2025 on admissibility of additional evidence, as under: “2.2 As stated above

Tapandeep Singh, Dehradun vs. Deputy Commissioner of Income Tax Circle 1(1)(1), Dehradun

In the result, this appeal is partly allowed for statistical purposes

ITA 232/DDN/2025[2022-2023]Status: DisposedITAT Dehradun11 Feb 2026AY 2022-2023

Bench: Shri Yogesh Kumar Us & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.232/Ddn/2025 िनधा"रणवष"/Assessment Year:2022-23 बनाम Tapandeep Singh, Deputy Commissioner Of House No.21/A, Govind Nagar, Vs. Income Tax, Race Course, Dehradun, Uttarakhand. National Faceless Appeal Centre Pan No.Bgsps7306A (Nfac), Circle 1(1)(1), Dehradun, Uttarakhand. अपीलाथ" Appellant ""यथ"/Respondent

Section 250

which was 1 TAPANDEEP SINGH not admitted for adjudication by the Ld. CIT(A), since the same were not accompanied by any application under Rule 46A of the I.T. Rules. The Ld. DR was, otherwise, agreeable to remanding back of this case. 2. We have gone through the facts ... remand this matter back to the file of Ld. CIT(A), for fresh adjudication. The assessee is expected to file any fresh evidence under Rule 46A and the Ld. CIT(A) would call for a remand report. 3. In the result, this appeal is partly allowed for statistical purposes. Order

Shri Arun Kumar, Haridwar vs. ITO, Haridwar

In the result, the appeal is allowed for statistical purpose

ITA 137/DDN/2024[2015-16]Status: DisposedITAT Dehradun11 Feb 2026AY 2015-16

Bench: Shri Yogesh Kumar Us & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.137/Ddn/2024 िनधा"रणवष"/Assessment Year:2015-16 बनाम Arun Kumar Commissioner Of Income Tax, S/O Shri Ram Pal Singh, Vs. (Nfac, Delhi), Village Kutubpur, Garamerpur, Income Tax Office, Haridwar, Haridwar, S.O. Haridwar 249401, Uttarakhand. Uttarakhand, India. Pan No.Chcpk6029C अपीलाथ" Appellant ""यथ"/Respondent

Section 250

file of Ld. CIT(A) for fresh adjudication. The assessee would be at liberty to file any documents in his favour under Rule 46A and the Ld. CIT(A) would be at liberty to call for a remand report from the Ld. AO.The Ld. CIT(A) would also adjudicate

ACIT, C 2(1)(1), Agra vs. Sunil Kumar Joshan, Agra

In the result, the appeal of the revenue is dismissed and cross objection of the assessee is dismissed as infructuous

ITA 494/AGR/2025[2014-15]Status: DisposedITAT Agra11 Feb 2026AY 2014-15

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singhacit, Vs. Sunil Kumar Joshan, Foot On Shoes, 7Th Circle-2(1)(1), Agra Km Stone, Agra Delhi Bye Pass Road, Agra (Appellant) (Respondent) Pan: Abqpj4015P Co 07/Agr/2025 (In Ita No.494/Agr/2025) (Assessment Year: 2014-15) Sunil Kumar Joshan, Vs. Acit, Foot On Shoes, 7Th Km Circle-2(1)(1), Stone, Agra Delhi Bye Agra Pass Road, Agra (Appellant) (Respondent) Pan: Abqpj4015P

For Appellant: Shri Sahib P. Satsangi, CAFor Respondent: Shri Sukesh Kumar Jain, CIT DR
Section 143(3)Section 68

assessee before the learned NFAC which was not put to test by the learned AO thereby violating principles of natural justice in terms of Rule 46A of the Income Tax Rules. Per Contra, the learned AR submitted that absolutely no additional evidences were furnished before the learned NFAC ... there were no additional evidences filed by the assessee before the Learned NFAC and accordingly the argument of the learned DR regarding violation of Rule 46A of the IT Rules is hereby dismissed. Hence, I have no hesitation to hold that despite all the contemporaneous documentary evidences placed on record

M/S Dream Group, Raipur vs. Income Tax Officer-1(1), Raipur

In the result, appeal of the assessee in ITA

ITA 100/RPR/2025[2014-15]Status: DisposedITAT Raipur11 Feb 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. / Ita No.100/Rpr/2025 "नधा"रण वष" / Assessment Year : 2014-15 M/S. Dream Group Shop No.34, Ground Floor, Rio Complex, Opportunity. Fruit Market, Lalpur, Raipur (C.G.)-492 001 (C.G.) Pan: Aakfd1607J ........अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(1), Raipur (C.G.) ……""यथ" / Respondent

For Appellant: Shri R.B Doshi, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 69

admitted by the Tribunal as additional evidences so to be forwarded the same to the Ld. CIT(Appeals)/NFAC for compliance with Rule 46A(3) of the IT Rules, 1962, calling for a ground report from the A.O and then the First Appellate Authority shall decide the matter. In this ... conceded that in the interest of substantive justice, matter may be remanded to the file of the Ld. CIT(Appeals)/NFAC for compliance with Rule 46A(3) of the IT Rules, 1962, calling for a ground report from the A.O and at the same time, decide the matter afresh after

Institute of Orient Philosophy, Vrindavan vs. The Deputy Commissioner of Income Tax, Exemption Circle, Ghaziabad

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

ITA 6564/DEL/2025[2013-14]Status: DisposedITAT Delhi11 Feb 2026AY 2013-14

Bench: Sh. Sudhir Kumar, Judicial, Member & Sh. Manish Agarwal, Accountant, Member Assessment Year: 2013-14 Institute Of Orient Vs. The Deputy Commissioner Philosophy Of Income Tax, Raman Reti Vrindavan (Exemption) Circle, Mathura Uttar Pradesh- Ghaziabad Up 281121 Pan No. Aaat7158M (Appellant) (Respondent)

Section 11Section 12Section 12ASection 142(1)Section 143(3)Section 144Section 147Section 148

following grounds in appeal as under: 1. Because, learned CIT(Appeals) has erred and wrongfully held that the ‘Appellant’ had filed additional evidence under rule 46A and certain facts like registration u/s 12AA were not brought to the notice of the AO during assessment proceedings. 2. Because, learned CIT(Appeals ... order as under: “6.1.1 Now before me in the appellate proceedings, the appellant has filed written submission. The appellant has filed additional evidences under Rule 46A of the Income Tax Rule before me. The appellant has stated that it is a society and registration has been granted