Additional evidence in tax appeals requires a rebuttal opportunity, and exemption claims cannot be allowed without it.

Additional evidence at the appellate stage may be received only in the limited circumstances permitted by the statutory scheme, and the assessing authority must be given a reasonable opportunity to challenge or rebut it. The first appellate authority had accepted the forms as additional evidence and remanded the matter for verification, which preserved that opportunity. The Tribunal erred by allowing the exemption claims straightaway on the basis of those forms, thereby bypassing the mandatory rebuttal process. Its order was therefore unsustainable, and the matter was required to follow the remand route for verification and lawful reconsideration.

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Issues: Whether the Tribunal was justified in allowing exemption claims based on additional evidence filed for the first time before the first appellate authority without giving the assessing authority an opportunity to challenge or rebut the material under the statutory scheme governing additional evidence.

Analysis: The statutory rule against production of additional evidence at the appellate stage permits such evidence only in specified circumstances, and in every such case reasonable opportunity must be afforded to the assessing authority for challenge or rebuttal. The first appellate authority accepted the forms as additional evidence and remanded the matter for verification, which preserved the statutory opportunity. The Tribunal, however, straightaway allowed the exemption claims on the basis of those forms and thereby bypassed the mandatory rebuttal opportunity. This was contrary to the express requirement governing additional evidence and rendered the Tribunal's interference unsustainable.

Conclusion: The Tribunal's order could not be sustained and the revisional court held that the matter had to go back to the first appellate authority's course of remand for verification and lawful reconsideration.

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