Additional evidence under ITAT Rule 29 and Section 54F exemption raise substantial questions of law in the appeal.

The commentary addresses whether the Tribunal must first decide an application to admit additional evidence under Rule 29 of the ITAT Rules, 1963 before examining the merits, whether denial of exemption under Section 54F was justified, and whether the appellant had a fair opportunity to rebut conclusions drawn from additional evidence and Circular No. 495 dated 22.09.1987. The High Court admitted the appeal on these substantial questions of law and directed it to be listed for further directions.

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Issues: Whether the Tribunal was required to decide the application for admission of additional evidence under Rule 29 of the Income-tax Appellate Tribunal Rules, 1963 before dealing with the merits; whether the denial of exemption under Section 54F was justified; and whether the appellant was denied an opportunity to rebut conclusions drawn from additional evidence and Circular No. 495 dated 22.09.1987.

Outcome: The appeal was admitted on the stated substantial questions of law and listed for directions.

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