“rule 46A”

AppealsRule 46ARule 46A2,967 judgments

The decision most relied on for rule 46A is CIT v. Divine Leasing & Finance Ltd. (299 ITR 268), cited in 426 judgments on BharatTax.

Leading authorities on rule 46A

CIT v. Divine Leasing & Finance Ltd.

299 ITR 268 · 2008 · High Court

426

citing judgments

The Assessing Officer cannot add share capital or share premium amounts if the assessee provides the identity and creditworthiness of the subscriber and establishes the genuineness of the transaction. The court may admit additional evidence under Rule 46A, such as the PAN identity of the creditor.

CIT v. Jansampark Advertising & Marketing (P.) Ltd.

56 Taxmann.com 286 · 2015 · High Court

196

citing judgments

The Commissioner of Income-tax (Appeals) has an independent statutory obligation to conduct proper inquiries and verify facts, especially when the Assessing Officer has failed to do so. The CIT(A) must ensure effective inquiry is carried out before deleting additions or accepting additional evidence.

Smt. Prabhavati S. Shah v. CIT

231 ITR 1 · 1998 · High Court

186

citing judgments

The first appellate authority must admit additional evidence if it is necessary for determining the true state of affairs and preventing undue hardship or a failure of justice, even without a specific request and particularly when the case falls under Rule 46A(1)(c).

CIT v. Manish Build Well (P) Ltd.

16 Taxmann.com 27 · 2011 · High Court

120

citing judgments

The CIT(A) must strictly comply with Rule 46A of the Income-tax Rules for admitting additional evidence, ensuring all prescribed conditions exist, reasons are recorded, and reasonable opportunity is provided to the Assessing Officer.

CIT v. Nikunj Eximp

216 Taxmann.com 171 · 2013 · High Court

103

citing judgments

The Assessing Officer must consider additional evidence produced before the CIT(A) under Rule 46A and cannot reject it without proper appreciation of the facts, especially when the assessee was prevented by sufficient cause from producing it earlier.

CIT v. Virgin Securities & Credits (P) Ltd.

332 ITR 396 · 2011 · High Court

citing judgments

The Commissioner of Income-tax (Appeals) must admit additional evidence if it is crucial for the proper disposal of the appeal, ensuring substantial justice to the appellant.

CIT v. Manish Buildwell (P) Ltd.

245 CTR 397 · 2011 · High Court

citing judgments

The production of fresh evidence at the appellate stage before the Commissioner (Appeals) is strictly governed by the conditions and procedures laid down in Rule 46A of the Income-tax Rules.

CIT v. Ranjit Kumar Choudhury

288 ITR 179 · 2007 · High Court

citing judgments

The appellate authority must follow Rule 46A of the Income Tax Rules when admitting additional evidence, which includes recording reasons for admission and providing the Assessing Officer an opportunity to verify or refute the evidence. Failure to do so violates principles of natural justice.

Judgments citing rule 46A

Assistant Commissioner of Incometax, Exemptions, Circle, Pune vs. Shree Warana Vibhag Shikshan Mandal, Warnanagar

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

ITA 987/PUN/2024[2017-2018]Status: DisposedITAT Pune21 Apr 2025AY 2017-2018

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

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Ajay Kumar Keshari

Section 11Section 12ASection 142(1)Section 143(1)Section 144Section 80G

12AA and 80G and written submission. Since these were not submitted during assessment stage, a remand report was called for from the AO under Rule 46A of the IT Rules vide order dated 22.02.2024. The remand report was due by 04.03.2024. However the report has not been received. 6.3 When ... circumstances led to the ex-parte order passed by the Ld. AO. He submitted that the Ld. CIT(A) has controverted the provisions of Rule 46A of the Income Tax Rules, 1962 by admitting the additional evidence filed by the assessee before him. In support thereof, the Ld. DR placed

Mr. Anil Bherumal Kalal, Mumbai vs. ITO -19(2)(1), Mumbai

In the result, substantial ground of appeal raised by assessee is allowed

ITA 1189/MUM/2025[2006-07]Status: DisposedITAT Mumbai21 Apr 2025AY 2006-07

Bench: Shri Pawan Singh(Physical Hearing) Mr. Anil Bherumal Kalal Ito – 19(2)(1), Mumbai A-602, Pooja Enclave, S T Braz Road, Kautilya Bhavan, Bkc, Vs. Behind Nanavati Hospital, Vile Parle Bandra (East), Mumbai – West, Mumbai-400056. 400051. Pan: Aabpk 3216 B (Appellant) (Respondent) Assessee By : Shri Subhash Chhajed, Ar Revenue By : Ms. Pradnya Gholap, Sr. Dr Date Of Hearing : 16.04.2025 Date Of Pronouncement : 16.04.2025 Order Under Section 254(1) Of Income Tax Act Per Pawan Singh: 1. This Appeal By Assessee Is Directed Against The Order Of Ld. Cit(A) Dated 30.12.2024 For A.Y. 2006-07. The Assessee Has Raised The Following Grounds Of Appeal: “Validity Of The Notice Under Section 143(2) Of The Act & The Assessment Thereunder: 1.A) On The Facts & In The Circumstances Of The Case & In Law, The Learned Commissioner Of Income Tax (Appeals) [Cit (A)] Erred In Upholding The Assessment For The Assessment Year 2006-07 Framed By The Learned Assessing Officer Without Complying With The Relevant Provisions Of The Law. B) It Is Respectfully Submitted That No Notice Under Section 143(2) Of The Act Was Served On The Appellant Within The Time Limits Prescribed Under Section 143(2) Of The Act. Accordingly, The Learned Assessing Officer Had No Jurisdiction To Proceed With Scrutiny Assessment Under Section 143(3) Of The Act. Thus, The Assessment Is Bad In Law & Deserves To Be Quashed & Struck Down As Null & Void. In View Of The Above, The Appellant Prays That The Assessment Be Set Aside As Bad In Law & Struck Down As Null & Void.

For Appellant: Shri Subhash Chhajed, ARFor Respondent: Ms. Pradnya Gholap, Sr. DR

Section 143(2)Section 143(3)Section 144Section 254(1)Section 54FSection 69

assessee while explaining the fact before ld. CIT(A) furnished of necessary evidence to prove the source of investment. The assessee also filed application Rule 46A of Income Tax Rules for admission of additional evidence to substantiate the source of investment. On the submission and 4 Mr. Anil Bherumal Kalal

Ashok Gupta HUF, Alwar vs. DCIT, Central Circle, Alwar

In the result, the appeal filed by the assessee is disposed off for

ITA 52/JPR/2025[2018-19]Status: DisposedITAT Jaipur17 Apr 2025AY 2018-19

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Sh. Gautam Singh Choudhary, JCIT

Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153CSection 250Section 56(2)(ix)

provisions of section 56(2)(ix) made the addition of Rs.20,01,000/- 4. Before Ld. CIT(A) assessee filed application dt. 13.06.2024 under Rule 46A for admission of additional evidences regarding cancellation of sale agreement with Sh. Sunil Gupta (PB 27-33), affidavit of Sunil Gupta regarding return ... filed 11 Ashok Gupta HUF vs. DCIT any evidence that there was issue of encroachment. Accordingly he held that documents filed under Rule 46A are colourable device, not bonafide and are created to avoid the payment of legitimate tax and thus the additional evidence are not admitted. Thereafter

Sh. Mahesh Kumar Dhariwal, Jhalawar vs. ITO, Ward-Jhalawar, Jhalawar

In the result the appeal of the assessee is allowed

ITA 1406/JPR/2024[2017-18]Status: DisposedITAT Jaipur17 Apr 2025AY 2017-18

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Appellant: Mr. P. C. Parwal, C.A., Ld. ARFor Respondent: Mr. Anup Singh, ADDL. CIT, Ld. DR

Section 115BSection 139(1)Section 145Section 250Section 68

Aadhar Card, Booking Order and ledger accounts before the Ld. CIT (A) and he was duty bound to entertain the same complying with the Rule 46A of the Rules. But, instead of that he simply refused to accept the same, which is again against the principles of natural justice

Asst. Commissioner of Income Tax, Panvel vs. Flowline Systems Pvt Ltd, New Panvel

In the result, appeal of the Revenue is dismissed

ITA 2168/PUN/2024[2021-22]Status: DisposedITAT Pune17 Apr 2025AY 2021-22

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.2168/Pun/2024 िनधा"रण वष" / Assessment Year: 2021-22 Assistant Commissioner V Flowline Systems Pvt. Ltd., Of Income Tax, S 401, 402, Bhoomi Landmark, Panvel. New Panvel, Dist-Raigad. Maharashtra – 410206. Pan: Aabcf1096R Appellant / Revenue Respondent / Assessee Assessee By Shri A R Sakhalkar & Shri M.R.Dharmadhikari –Ar’S Revenue By Shri Ramnath P Murkunde – Dr Date Of Hearing 20/03/2025 Date Of Pronouncement 17/04/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Revenue Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, Dated 14.08.2024 For A.Y.2021-22 Emanating From Order Under Section 154 Of The Income Tax Act, 1961 Issued By Adit(Cpc), Bangalore. The Revenue Has Raised The Following Grounds Of Appeal :

Section 154Section 250Section 250(4)Section 46A(3)

available before the Assessing Officer. Thus, ld.CIT(A) has not admitted any new evidence, hence, ITA No.2168/PUN/2024 [A] there is no violation of Rule 46A of the Income Tax Rules. Therefore, Ground No.“b” of the Revenue is dismissed. 8. Ld.CIT(A) has verified the facts from the record

Sangeeta Agrawal L.H of Late Sh. Rakesh Kumar Agrawal, Delhi vs. ACIT, Circle-60(1), New Delhi, Delhi

The Appeal of the Assessee is partly allowed for statistical purpose

ITA 4668/DEL/2024[2014-15]Status: DisposedITAT Delhi17 Apr 2025AY 2014-15

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalsangeeta Agrawal L. H Of Vs. Acit Late Sh. Rakeshkuamr Circle-60(1) Agrawal, New Delhi Sangeeta Agrawal L/H Of Late Sh. Rakesh Kumar Agrawal, New Delhi Pan: Afipa6968A Appellant Respondent

Section 133(6)Section 143(3)

27/09/2024, dismissed the Appeal filed by the Assessee, wherein the Ld. CIT(A) has dismissed the Application filed for admission of additional evidence under Rule 46A of the Income Tax Rules, 1962. As against the order of the Ld. CIT(A) dated 27/09/2024, the Assessee preferred the present Appeal ... opined that the Assessee has failed to establish that it is covered in any of the 3 Sangeeta Agrawal L.H Vs. ACIT limbs of Rule 46A of the Rules. The Assessee has rebutted the version of the A.O. contending that the Assessee was asked to produce certain person in case

Kunguman Ganeshan, Chennai vs. ITO, Ncw-11(3), Chennai

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

ITA 295/CHNY/2025[2017-18]Status: DisposedITAT Chennai17 Apr 2025AY 2017-18

Bench: Shri George George K., Vice- & Shri S.R. Raghunathaआयकरअपीलसं./Ita No.: 295/Chny/2025 िनधा"रणवष" / Assessment Year: 2017-18 Kunguman Ganeshan, Income Tax Officer, 22/59, Mohammed Hussain Street, Vs. Non Corporate Ward -11(3), Royapettah S.O., Royapettah, Chennai 600 006. Chennai 600 014. [Pan: Bgqpg-5503-H] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri J. Saravanan, Advocate ""थ"कीओरसे/Respondentby : Shri A. Sasi Kumar, Cit सुनवाईकीतारीख/ Date Of Hearing 18.03.2025 : घोषणाकीतारीख /Date Of Pronouncement : 17.04.2025 आदेश /O R D E R Per S. R. Raghunatha: This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 06.11.2024 & Pertains To Assessment Year 2017-18 Under Section 250 Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri J. Saravanan, AdvocateFor Respondent: Shri A. Sasi Kumar, CIT

Section 133(6)Section 142(1)Section 250Section 69A

assessee carried the matter in appeal before the ld. CIT(A) and furnished additional grounds/fresh evidence. In order to satisfy the provisions of Rule 46A of the Income Tax Rules, the ld. CIT(A) sought for the remand report from the Assessing Officer. The Assessing Officer :-3-: ITA. No: 295/Chny/2025

Bses Rajdhani Power Ltd., New Delhi vs. ACIT, Cicle- 5(1), New Delhi

ITA 4850/DEL/2017[2007-08]Status: DisposedITAT Delhi16 Apr 2025AY 2007-08

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 132Section 143(1)Section 143(2)Section 148

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

Income Tax Officer, Vizianagaram vs. Chitripu Umamaheswara Rao, Vizianagaram

In the result, the appeal of revenue is dismissed

ITA 509/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam15 Apr 2025AY 2017-18

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.509/Viz/2024 (निर्धारण वर्ा/Assessment Year:2017-18) Income Tax Officer, Shri Chitripu Umamaheswara Rao, Vs. Vizianagaram. Vizianagaram. Pan:Aawpu2149L (Appellant) (Respondent) C.O. No.04/Viz/2025 (Assessment Year : 2017-18) (By Assessee) निर्धाररती द्वधरध/Assessee By: Shri G.V.N. Hari, Advocate रधजस् व द्वधरध/Revenue By:: Dr. Satyasai Rath, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 24/03/2025 घोर्णध की तधरीख/Pronouncement: 15/04/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri G.V.N. Hari, AdvocateFor Respondent: : Dr. Satyasai Rath, CIT-DR

Section 147Section 148

from the Ld. AO despite the assessee submitting the development agreement as additional evidence before the Ld. CIT(A), which is a violation of Rule 46A of the I.T. Rules, 1962. Finally, the Ld. DR prayed before the bench to set aside the order of Ld. CIT(A) for fresh ... agreement. Accordingly, the Ld. AR submitted that, the Ld. AO had already considered the documents during assessment. Hence, the question of additional evidence under Rule 46A does not arise. Therefore, the objection of the Ld. DR on account of additional evidence is liable to be rejected. 7. We have heard

DCIT, New Delhi vs. Best Agrolife Limited, New Delhi

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

ITA 4024/DEL/2024[2022-23]Status: DisposedITAT Delhi15 Apr 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri S.Rifaur Rahman

For Appellant: NoneFor Respondent: Shri Ashish Tripathi, Sr. DR

Section 143(1)

advance tax credits without providing an opportunity to the Assessing Officer ITA No.4024/DEL/2024 or to CPC, Bengaluru, which is in contravention of provisions of Rule 46A of the Income Tax Rule, 1962 as per the judgement by Hon'ble ITAT Hyderabad in ITA No. 586/Hyd/2022 in the matter of DCIT ... JCIT (A) granted relief to the assessee. However, he argued that Id. JCIT (A) has accepted the additional evidences submitted by the assessee under Rule 46A without giving opportunity to the AO. Considered the submissions of the Id. DR of the Revenue and relevant findings of Id. JCIT

DCIT, Circle-3, Ludhiana vs. M/S Ganeshay Overseas Industries Limited, Chandigarh

In the result, Appeal of the Revenue is dismissed

ITA 361/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh11 Apr 2025AY 2017-18

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Chandrajit Singh, CIT DR

Section 68

assesse. 4. Whether a reasonable opportunity should be given to the Assessing Officer to examine the documents submitted as an additional evidence under Rule 46A by the appellant before the Ld. CIT(A) or not. 5. The appellant craves leave to add, amend, modify, vary, omit or substitute ... attention with regard to the ground that no reasonable opportunity has been given to the AO on account of additional evidences submitted under Rule 46A. He further argued that since the ITR of those parties are showing a huge loss, thus, the capacity to advance the loan by the parties

Pawan Kumar Singla, Panchkula vs. DCIT, CC-I, Chandigarh

In the result, the assessee's appeal on the various grounds raised

ITA 12/CHANDI/2018[2012-13]Status: DisposedITAT Chandigarh11 Apr 2025AY 2012-13

For Appellant: Shri Ajay Jain, C.AFor Respondent: Smt. Kusum Bansal, CIT, DR

Section 132oSection 143(2)Section 153ASection 153DSection 271(1)(c)

Ground 2, the CIT(A) allowed a deduction of Rs.63,778 under Chapter VI-A after accepting additional evidence (insurance premium receipts) under Rule 46A. The documents had initially been unavailable due to their misplacement during the search, but were later produced during the appeal. In Ground 3, involving

Pawan Kumar Singla, Panchkula vs. DCIT, CC-I, Chandigarh

In the result, the assessee’s appeal on the various grounds raised is dismissed

ITA 11/CHANDI/2018[2011-12]Status: DisposedITAT Chandigarh11 Apr 2025AY 2011-12

Bench: Final Hearing.

For Appellant: Shri Ajay Jain, C.AFor Respondent: Smt. Kusum Bansal, CIT, DR

Section 132oSection 143(2)Section 153ASection 153DSection 271(1)(c)

Ground 2, the CIT(A) allowed a deduction of Rs. 63,778 under Chapter VI-A after accepting additional evidence (insurance premium receipts) under Rule 46A. The documents had initially been unavailable due to their misplacement during the search, but were later produced during the appeal. In Ground 3, involving

ITO, Ward-2, Rohtak vs. Jai Singh, Rohtak

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

ITA 8284/DEL/2018[2010-11]Status: DisposedITAT Delhi11 Apr 2025AY 2010-11

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singh[Assessment Year: 2010-11]

Section 144Section 147Section 148Section 274

challenged in view of the cash flow statement and source of deposit explained by the assessee. Additional evidences given by the assessee was under Rule 46A of the I.T. Rules were sent to the AO for his comments. Vide remand report's dated 03.01.2018 and 20.09.2018 the AO stated that

Shri Dariyalal Sarvajanik Trust, Mumbai vs. ITO (Exemption), Mumbai

ITA 755/MUM/2025[2010-11]Status: DisposedITAT Mumbai11 Apr 2025AY 2010-11

Bench: Smt. Beena Pillai (Jm) & Shri Omkareshwar Chidara (Am) Shri Dariyalal Sarvajanik Ito Ward 2(3) Trust Mtnl Building 33, Dariyasthan Street Vs. Cumbala Hill Mandvi S.O. Mumbai Pedder Road Mumbai-400 003. Mumbai-400026. Pan : Aabts3725P Appellant Respondent

For Appellant: Shri Pravin SalukheFor Respondent: Shri Anil Thakrar

Section 144Section 148

investment in this Government Bond. These details of copy of certificates of Government Bonds were filed for the first time before the ITAT under Rule 46A of the 3 I.T. Rules as additional evidence to be considered without any explanation as to why the same was not filed before lower

Kawaljeet Dhanrajsing Ranawat, Jaipur vs. ACIT, Circle, Amrawati

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

ITA 594/JPR/2024[2016-17]Status: DisposedITAT Jaipur10 Apr 2025AY 2016-17

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. Ankit Bubna, CA, Ld. ARFor Respondent: Mrs. Anita Rinesh, JCIT, Ld. DR

Section 133(6)Section 139(4)Section 143(3)Section 250Section 68

Bank Statement. Although the same were not considered by the Ld. CIT(A) as the assessee has not filed any application as provided in Rule 46A of the I.T. Rules, 1962. Still, the same information was not provided for remaining two parties, i.e. Atharwa Associates and Prashant Pattiwal ... creditors, but as the Ld. CIT(A) ignored the evidences on a technical ground that no application has been filed as per Rule 46A of the Rules, hence information pertaining to Geetaben Bharat Oswal was not considered/entertained. We deem it fit to relax this condition as far as information pertaining

Incometax Officer, Non Corporate Ward 2(4), Kochi vs. Kochin Co Operative Society Ltd, Mattancherry

In the result, the appeals filed by the Revenue stand partly allowed

ITA 663/COCH/2023[2013-14]Status: DisposedITAT Cochin09 Apr 2025AY 2013-14

Bench: Shri George George K., Vp & Shri Inturi Rama Rao, Am

For Appellant: Shri Sanjit Kumar Das, CIT-DRFor Respondent: Ms. Niveditha K. Kammath, Advocate

Section 139(1)Section 144Section 148Section 69ASection 80P

submits that the order passed by the CIT(A) is in total violation of the principles of natural justice under the provisions of rule 46A of the Income Tax Rules. Therefore, he submits that the matter may be remanded back to the file of CIT(A) for fresh disposal ... ought not have accepted the submission of the appellant without calling for a remand report from the AO in terms of provisions of rule 46A of the I.T. Rules. Therefore, the order of the CIT(A) is hereby set aside and remitted back to the file of Kochin Co-opertive

Income Tax Officer, I S Press Road, Kochi vs. Kochin Co Operative Society Ltd, Mattancherry

In the result, the appeals filed by the Revenue stand partly allowed

ITA 644/COCH/2023[2014-15]Status: DisposedITAT Cochin09 Apr 2025AY 2014-15

Bench: Shri George George K., Vp & Shri Inturi Rama Rao, Am

For Appellant: Shri Sanjit Kumar Das, CIT-DRFor Respondent: Ms. Niveditha K. Kammath, Advocate

Section 139(1)Section 144Section 148Section 69ASection 80P

Jagdishsinh Bhagwansinh Mahida, Na vs. Arivs.the ACIT, Anand Circle, Anand

ITA 1970/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad09 Apr 2025AY 2012-13

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri Chitrang Vaywala, ARFor Respondent: Shri Kavan Limbasiya, Sr DR

Section 144Section 250Section 50C

appeal filed by the assessee only on the ground that no petition has been filed by the assessee for admission of additional evidence under Rule 46A of the IT Rules. Jagdishsinh Bhagwansinh Mahida Vs.ACIT Asst. Year : 2012-13 - 2– 2. On the facts and circumstances of the case as well

Deepali Manish Shrivastava, Pune vs. Income Tax Officer Ward 6(1) Pune, Pune

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

ITA 2547/PUN/2024[2018-19]Status: DisposedITAT Pune09 Apr 2025AY 2018-19

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Umesh Kumar M. MaliFor Respondent: Ms. Shilpa N. C

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

evidences 8 which was claimed to be filed on 23.08.2024. In this regard, we find that the application for admission of additional evidences under Rule 46A is dated 23.08.2024 and the first appellate order passed by Ld. CIT(A)/NFAC is also dated 23.08.2024. Apparently, this application has not been ... application might be filed by the assessee on the same date but after passing the first appellate order, however, copy of application under Rule 46A produced by the assessee before Ld. CIT(A)/NFAC is unacknowledged copy. Along with this application which is claimed to be filed before