Additional evidence in income tax appeals is restricted unless specific exceptions apply and the Assessing Officer gets a fair rebuttal opportunity.

Additional evidence before the Joint Commissioner (Appeals) or the Commissioner (Appeals) is generally not allowed unless the appellant shows specified circumstances, including wrongful refusal by the Assessing Officer, sufficient cause for non-production, or lack of adequate opportunity. Admission of such evidence requires written reasons, and the Assessing Officer must be given a reasonable opportunity to examine, cross-examine, or rebut the evidence. The rule also preserves the appellate authority's power to call for documents or witnesses for substantial cause, including enhancement of assessment or penalty or imposition of penalty.

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