“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

Alfa Modern Mobiles Private Limited, Delhi vs. Income Tax Officer Ward 2(1), Cr Building

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

ITA 5701/DEL/2024[2017-18]Status: DisposedITAT Delhi11 Feb 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2017-18] Alfa Modern Mobiles Pvt. Ltd., Vs Ito A-24/2, Naraina Industrial Ward-2(1) Area, Phase-I, C.R. Building New Delhi-110028. Delhi-110001 Pan-Aaica6087C Appellant Respondent Appellant By Shri Pranshu Goel, Ca & Shri Aditya Gupta, Adv. Respondent By Shri Ajay Kumar Arora, Sr.Dr Date Of Hearing 04.02.2026 Date Of Pronouncement 11.02.2026

Section 142(1)Section 143(2)Section 143(3)Section 145(3)Section 250Section 40Section 44ASection 46ASection 69A

unwarranted, as the required TDS details were available and provided. 7. That the learned CIT(A) erred in rejecting the additional evidence under Rule 46A despite the fact that sufficient cause was shown for the delay in submitting such evidence. Moreover the additional evidences was only in respect of following ... assessee on merits by observing that no details were filed before the AO and all the relevant details have now been submitted under Rule 46A of the Income Tax Rules, 1962 before him. Ld. CIT(A) further observed that assessee has been able to tender the reason for not filing

Income Tax Officer, Ward-20(1), Delhi vs. Prem Softech Private Limited, Udyog Vihar, Gurugram

The appeal of the revenue is dismissed

ITA 3160/DEL/2024[2014-15]Status: DisposedITAT Delhi11 Feb 2026AY 2014-15

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Sh. Manish Jaggi, DirectorFor Respondent: Sh. Ajay Kumar Arora, Sr. DR

Section 144BSection 147Section 147rSection 194ASection 194C

circumstances of the case, the Ld. NFAC erred in admitting the additional evidences without calling for remand report from the assessing officer, as per rule 46A of the Income-tax Rules. Whether on the facts and circumstances of the case, the Ld. NFAC erred in deleting the addition ... raised above at the time of hearing of this appeal." The ld. DR has primarily contended that additional evidence were admitted in violation of Rule 46A of the Income Tax Rules and on merits it was submitted that assessee company had claimed to have received funds for software development when

Deputy Commissioner of Income Tax -1(1), Raipur vs. Bharat Agro Industries, Raipur

In the result, the appeal of the Revenue is partly allowed as above

ITA 511/RPR/2025[2015-16]Status: DisposedITAT Raipur10 Feb 2026AY 2015-16

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am

For Appellant: Shri Jalaj Prakash, AdvocateFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 133(6)Section 250Section 40A(3)

Raipur vs. Bharat Agro Industries, Raipur for the purchase of Cassia Tora seeds, by admitting additional evidences in contravention of Income Tax Rules 46A(1) and 46A(2) and there by ignoring the facts brought on the record by the AO. 2. Without prejudice to the above, whether ... facts and circumstances of the case and in law, the Ld. CIT(A) was justified in ignoring violation of Income Tax Rule 46A(3) without appreciating that a) the additional evidences admitted were not forwarded to the AO and remand report was not called from him and, accordingly

Assistant Commissioner of Income Tax, Central Circle-2(1), Chennai vs. M/S Radaan Media Works India Limited, Teynampet

In the result, appeal of the revenue is dismissed

ITA 2136/CHNY/2025[2015-16]Status: DisposedITAT Chennai10 Feb 2026AY 2015-16

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita No.2136/Chny/2025 "नधा"रण वष"/Assessment Year: 2015-16 V. Acit, M/S Radaan Media Works Central Circle 2(1), India Limited, Chennai-600034 14 Jayammal Road, Chennai -600018 [Pan: Aabcr3815L] (अपीलाथ"/Assessee) (""यथ"/Respondent)

Section 131Section 132Section 132(44)Section 133ASection 142(1)Section 153CSection 69C

impugned transactions & failed to appreciate and follow the Principle of law enunciated therein. 5. The Ld.CIT(A) erred in not giving opportunity under Rule 46A of the I.T.Rules 1962 despite recording in the order that the assessee has provided evidence to the fact that the impugned transactions were already recorded ... date of survey but never gave an opportunity to the Assessing Officer as to what the evidence was, thereby violating the provisions of Rule 46A of I.T.Rules, in respect of new evidences brought in at the appellate stage for the first time. 6. For these grounds and any other ground

Ekesh Gaurang Desai, Mumbai vs. Central Circle - 1(1), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 6116/MUM/2025[2011-12]Status: DisposedITAT Mumbai10 Feb 2026AY 2011-12

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokarekesh Gaurang Desai Vs Acit Central Circle -1(1), Mumbai C-46, Pandurang Chs, A.B. 321, Aayakar Bhavan, M.K. Road, Nair Road Near Juhu Post Mumbai 400020 Office, Juhu Mumbai-400049 Pan:Aibpd4569L Appellant Respondent Assessee By : Shri Dharangandhi, Adv & Ms. Vinita Nara Adv Respondent By : Shri Ritesh Misra (Cit Dr) Date Of Hearing : 29/01/2026 Date Of Pronouncement : 10/02/2026 O R D E R Per: Anikesh Banerjee (Jm): The Instant Appeal Of The Assessee Filed Against The Order Of The Ld. Commissioner Of Income Tax (Appeal)-47, Mumbai [For Brevity ‘The Ld. Cit(A)’], Order Passed Under Section 250 Of The Income Tax Act 1961 (For Brevity ‘The Act’) For Assessment Year 2011-12, Date Of Order 28.07.2025. The Impugned Order Emanated From The Order Of The Ld. Income-Tax Officer Ward-22(1)(2), Mumbai

For Appellant: Shri DharanGandhi, Adv & Ms. Vinita Nara AdvFor Respondent: Shri Ritesh Misra (CIT DR)

Section 139(1)Section 143(3)Section 153ASection 250

total income of the assessee. Being aggrieved assessee filed an appeal before the Ld. CIT(A). The assessee filed the additional evidence under Rule 46A of the Income Tax Rule, 1962 (in short, the ‘Rules’) before the Ld. CIT(A). And the Ld. CIT(A) called for remand report

Shree Nana Jadra Seva Sahkari Mandli Limited, Bhavnagar vs. The ITO, Ward-1(9), Bhavnagar

The appeal of the assessee is treated as allowed for statistical purposes

ITA 2570/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2018-19

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.2570/Ahd/2025 िनधा"रण वष" /Assessment Year : 2018-19 Shree Nana Jadra Seva Sahkari The Ito बनाम/ Mandli Ltd. Ward-1(9) V/S. At Nana Jadra Village Bhavnagar – 364 001 Mahuva Bhavnagar – 364 290 "थायी लेखा सं./Pan: Aaxas 2474 E (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee By : Shri Nemish Shah, Ca Revenue By : Shri Rajenkumar M. Vasavda, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 02/02/2026 घोषणा की तारीख /Date Of Pronouncement: 09/02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 28/10/2025 For Assessment Year (Ay) 2018-19. 2. The Assessee, In This Appeal, Has Taken The Following Grounds Of Appeal: Shree Nana Jadra Seva Sahkari Mandli Ltd. Vs. Ito Asst. Year : 2018-19

For Appellant: Shri Nemish Shah, CAFor Respondent: Shri Rajenkumar M. Vasavda, Sr.DR

Section 69A

erred in not admitting the additional evidence furnished by the Appellant in accordance with the provisions of Rule 46A of the Income Tax Rules, 1962. 2. The Ld. CIT(A) failed to appreciate that the Appellant was prevented by sufficient and reasonable cause from producing the said evidence before

Income Tax Office Ward 3(3) Pune, Pune vs. Ramesh Magaramji Muleva, Pune

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

ITA 3120/PUN/2025[2018-19]Status: DisposedITAT Pune09 Feb 2026AY 2018-19

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

For Appellant: Shri Manish SomaniFor Respondent: Smt. Shraddha Nichal

Section 142(1)Section 143(2)Section 144BSection 147Section 148Section 251Section 69

admitted "additional evidence" but did not provide an opportunity to the Assessing Officer to examine the same before drawing conclusions, thereby violating Rule 46A(3). The order is contrary to law and deserves to be annulled. 4. The Ld. CIT(A) assumed powers to restore the matter ... /NFAC admitted the additional evidence without providing any opportunity to the Ld. AO to examine the same which is in violation of Rule 46A of the Income tax Rules. Further, the Ld. CIT(A)/NFAC‟s order also violates the provisions of section

Norma Joseph Baptista, Mumbai vs. Income Tax Officer, Ward 24 (3) (1), Piramal Chamber, Mumbai

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

ITA 7297/MUM/2025[2017-18]Status: DisposedITAT Mumbai09 Feb 2026AY 2017-18

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm Ms. Norma Joseph Baptista, Income Tax Officer, 65, Gauthan Lane, Opp Radio Club, Ward 24(3)(1) Vs. Andheri West, Lalbaug, Mumbai – 400 058 Mumbai – 400 012 Pan:Aflpb0834K (Appellant) (Respondent) :

For Respondent: Shri Leyaqat Ali Aafaqui, Sr. AR

Section 142(1)Section 144Section 250Section 69A

reason that the lower authorities have failed to admit the evidences filed by the assessee during the first appellate proceeding under rule 46A of the Income Tax Rules, 1962 (‘the Rules’ for short) without any reasonableness as to why the same was rejected. Further, it is also observed that

Income Tax Officer - 3(3)(1), Mumbai vs. Rak Construction Project Pvt. Ltd., Mumbai

The appeal of the assessee is allowed, and the appeal of the Revenue is dismissed

ITA 6091/MUM/2025[2018-19]Status: DisposedITAT Mumbai09 Feb 2026AY 2018-19

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

Section 142(1)Section 143(1)Section 143(2)Section 271ASection 68

loans. The Revenue has further challenged the acceptance of evidences by the Ld. CIT(A) during the appellate proceedings, contending that the provisions of Rule 46A of the Income Tax Rules, 1962 were not properly appreciated. 21. The core grievance of the Revenue is that the Ld. CIT(A) accepted

Rak Construction Project Pvt Ltd, Mumbai vs. Income Tax Officer Ward 3(3)(1), Mumbai

The appeal of the assessee is allowed, and the appeal of the Revenue is dismissed

ITA 5580/MUM/2025[2018-19]Status: DisposedITAT Mumbai09 Feb 2026AY 2018-19

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

Section 142(1)Section 143(1)Section 143(2)Section 271ASection 68

Income Tax Officer-16(2)(1), Mumbai vs. Bhavini Kartik Mehta, Mumbai

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

ITA 5266/MUM/2025[2017-18]Status: DisposedITAT Mumbai09 Feb 2026AY 2017-18

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-18

For Appellant: Mr. Vipul ShahFor Respondent: 16/12/2025

Section 56(2)(vii)Section 69

appellate proceedings without allowing a reasonable opportunity to the reasonable opportunity to the Assessing Officer in violation of Assessing Officer in violation of Rule 46A of the Income Tax Rules, 1962 OR remanding back Rule 46A of the Income Tax Rules, 1962 OR remanding back Rule 46A of the Income ... evidence, other than what was produced before the Assessing evidence, other than what was produced before the Assessing Officer, was filed in terms of Rule 46A of the Income-tax Rules, Officer, was filed in terms of Rule 46A of the Income Officer, was filed in terms of Rule 46A

DCIT-15(1)(1), Mumbai, Aayakar Bhavan Mumbai vs. Moksh Alloy Private Limited, Mumbai

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

ITA 4025/MUM/2024[2018]Status: DisposedITAT Mumbai09 Feb 2026

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopalassessment Year : 2018-19 Dcit-15(1)(1), Moksh Alloy Private Limited, Room No. 451, 1404, Tulip Regency Gardens, 4Th Floor, Vs. Sector 6, Aayakar Bhavan, Kharghar, Mumbai-400020. Navi Mumbai-410210. Pan : Aahcm4191J (Appellant) (Respondent) For Assessee : Ms. Krupa Gurav For Revenue : Shri Umashankar Prasad, Cit-Dr Date Of Hearing : 27-01-2026 Date Of Pronouncement : 09-02-2026 O R D E R Per Vikram Singh Yadav, A.M :

For Appellant: Ms. Krupa GuravFor Respondent: Shri Umashankar Prasad, CIT-DR

Section 143(3)Section 40Section 40A(3)Section 68Section 69C

appellate proceedings, the Assessing officer is also required to be provided an opportunity and his report should be called for as specifically provided in Rule 46A(3). Basis the assessee‟s application and after taking into consideration the remand report submitted by the Assessing officer, the Ld.CIT(A) can pass ... appropriate order u/s Rule 46A(2) either accepting or rejecting the 6 additional evidences and thereafter, the matter can be proceeded within examining the merits of the case. 8. In the instant case, on perusal of the impugned order, it is not clear whether the assessee has moved any application

M/S. Shakti Swaroop Enterprises, Raipur vs. Assessment Unit Income Tax Department, Raipur

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

ITA 708/RPR/2025[2020-21]Status: DisposedITAT Raipur06 Feb 2026AY 2020-21

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.708/Rpr/2025 "नधा"रण वष" /Assessment Year : 2020-21 M/S. Shakti Swaroop Enterprises 201, Rajat Apartments, 2Nd Floor, Farista Nursing Home, Byron Bazar, Raipur (C.G.)-492 001 Pan: Adnfs3280L

For Appellant: S/Shri P.C. Mohanty, Advocate &For Respondent: Dr. Priyanka Patel, Sr. DR

Section 250(4)

justice, the matter needs to be revisited by the first appellate authority considering all these additional evidences filed on record in compliance to Rule 46A(3) of the IT Rules, 1962. 5. Having heard the submissions of the parties herein, considering the documents on record and as per directives ... clear reasoning in the order itself which reveals that the said authority has arrived at a such conclusion through independent application of mind. Secondly, Rule 46A(3) of the IT Rules, 1962 shall be complied with so that a ground report can be obtained from the A.O regarding all these

Deputy Commissioner of Income Tax, Circle-3(3)(1), Mumbai vs. Zoetis India Limited, Mumbai

ITA 5984/MUM/2025[2018-19]Status: DisposedITAT Mumbai06 Feb 2026AY 2018-19

Bench: BEFORESHRI PAWAN SINGH (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

For Respondent: Revenue by

Section 115JSection 142(1)Section 143(2)Section 143(3)Section 35D

only need to 6 Zoetis India Limited. re-examine in light of the additional evidence furnished by the assessee. As per the provisions of Rule 46A such evidences can be admitted and to be referred to the ld. AO for examination of the same. The ld. AO in response

ACIT, New Delhi vs. Arjun Enterprises Private Limited, Mumbai

In the result, ground No.5 & 6 raised by the revenue are dismissed

ITA 4257/DEL/2025[2018-19]Status: DisposedITAT Delhi06 Feb 2026AY 2018-19

Bench: Satbeer Singh Godara & Shri S. Rifaur Rahmanacit , Vs. Arjun Enterprises Pvt. Ltd. New Delhi 711, Filix Commercial Complex, Opp Asian Paints L.Bs Marg Bhandup W Mumbai 400078 Maharashtra (Pan: Aahca 1448 A)

For Appellant: NoneFor Respondent: Sh. Jitender Singh, CIT DR

Section 133(6)Section 143(2)Section 40Section 68

grounds of appeal:- 1. On the facts and in the circumstances of the case, the Ld. CIT(A) erred in admitting additional evidence under Rule 46A of the Income Tax Rules, 1962, without recording any finding regarding non- availability of documents during assessment proceedings, in violation of Rule 46A

ACIT, New Delhi vs. Sh. Atul Bansal, New Delhi

In the result, grounds raised by the revenue are dismissed

ITA 2803/DEL/2017[2013-14]Status: DisposedITAT Delhi06 Feb 2026AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanatul Bansal, Vs. Acit, Central Circle 16 Farm No. 22, The Green Rajokri Delhi. New Delhi – 110 038. (Pan: Agcpb1274F) Acit, Central Circle 16, Vs, Atul Bansal Delhi Farm No. 22, The Green Rajokri New Delhi – 110 038. (Pan: Agcpb1274F) Assessee By : None Revenue By : Sh. Jitender Singh, Cit Dr Date Of Hearing : 18.11.2025 Date Of Order : 06.02.2026 O R D E R

For Appellant: NoneFor Respondent: Sh. Jitender Singh, CIT DR

Section 143(1)Section 143(2)Section 14ASection 2(22)(e)Section 54Section 54B

assessee that requisite evidences filed during the course of assessment and thus accepted the evidence in form of allotment letter which is violative of Rule 46A. 4. That the appellant craves leave to add, alter or amend any/all of the grounds of appeal before or during the course ... assessee is eligible to claim deduction u/s 54 of the Act. Accordingly, ground No.2 raised by the revenue is dismissed. 27. With regard to Rule 46A , we observed that revenue has raised ground No.3 with the plea that Assessing Officer was not provided proper opportunity whereas we observed that assessee

Sh. Atul Bansal, New Delhi vs. ACIT, New Delhi

In the result, grounds raised by the revenue are dismissed

ITA 2737/DEL/2017[2013-14]Status: DisposedITAT Delhi06 Feb 2026AY 2013-14

For Appellant: NoneFor Respondent: Sh. Jitender Singh, CIT DR

Section 143(1)Section 143(2)Section 14ASection 2(22)(e)Section 54Section 54B

Shri Shyam Oil Extractions Pvt. Ltd., Jangir-Champa, Janjgir-Champa vs. Assistant Commissioner of Income Tax-2(1), Bilaspur

In the result, appeal of the assessee in ITA No

ITA 55/RPR/2025[2018-19]Status: DisposedITAT Raipur05 Feb 2026AY 2018-19

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. / Ita Nos.52, 53, 54, 55 & 339/Rpr/2025 "नधा"रण वष" / Assessment Years : 2015-16, 2016-17, 2017-18 & 2018-19 Shri Shyam Oil Extractions Pvt. Ltd. Village: Banari, Janjgir, Janjgir-Champa (C.G.)-495 668 Pan: Aaocs2467G ........अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer/Acit-2(1), Ward-Janjgir-Champa (C.G.)/Bilaspur ……""यथ" / Respondent

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri Yogesh Kumar Sharma, CIT-DR &

Section 250

justice, the matter needs to be revisited by the first appellate authority considering all these additional evidences filed on record in compliance to Rule 46A(3) of the IT Rules, 1962. 14. Having heard the submissions of the parties herein, considering the documents on record and as per directives ... conclusion so that there is clear reasoning in the order itself which reveals that the said authority has arrived at a such conclusion. Secondly, Rule 46A(3) of the IT Rules, 1962 shall be complied with so that ground report can be obtained from the A.O regarding all those additional

Shri Shyam Oil Extractions Pvt. Ltd., Janjgir-Champa vs. Assistant Commissioner of Income Tax-2(1), Bilaspur

In the result, appeal of the assessee in ITA No

ITA 54/RPR/2025[2017-18]Status: DisposedITAT Raipur05 Feb 2026AY 2017-18

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri Yogesh Kumar Sharma, CIT-DR &

Section 250

justice, the matter needs to be revisited by the first appellate authority considering all these additional evidences filed on record in compliance to Rule 46A(3) of the IT Rules, 1962. 14. Having heard the submissions of the parties herein, considering the documents on record and as per directives ... conclusion so that there is clear reasoning in the order itself which reveals that the said authority has arrived at a such conclusion. Secondly, Rule 46A(3) of the IT Rules, 1962 shall be complied with so that ground report can be obtained from the A.O regarding all those additional

Shri Shyam Oil Extractions Pvt. Ltd., Janjgir-Champa vs. Assistant Commissioner of Income Tax-2(1), Bilaspur

In the result, appeal of the assessee in ITA No

ITA 53/RPR/2025[2016-17]Status: DisposedITAT Raipur05 Feb 2026AY 2016-17

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri Yogesh Kumar Sharma, CIT-DR &

Section 250

justice, the matter needs to be revisited by the first appellate authority considering all these additional evidences filed on record in compliance to Rule 46A(3) of the IT Rules, 1962. 14. Having heard the submissions of the parties herein, considering the documents on record and as per directives ... conclusion so that there is clear reasoning in the order itself which reveals that the said authority has arrived at a such conclusion. Secondly, Rule 46A(3) of the IT Rules, 1962 shall be complied with so that ground report can be obtained from the A.O regarding all those additional