Additional evidence admitted under Rule 29, with disputed issues remanded for fresh assessment after verification and hearing.

Additional evidence under Rule 29 of the ITAT Rules, 1963 was admitted because the documents were considered material to the dispute and necessary for proper examination of the issues. The Tribunal found that the evidence required verification at the Assessing Officer level and, in the interest of justice, set aside the disputed issues for fresh adjudication. The Assessing Officer was directed to reconsider the matter after giving the assessee adequate opportunity of hearing and deciding it in accordance with law.

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Issues: Whether additional evidence sought to be filed by the assessee ought to be admitted and, if admitted, whether the matter should be remanded to the Assessing Officer for fresh adjudication.

Analysis: The assessee sought admission of additional evidence under Rule 29 of the ITAT Rules, 1963, contending that the documents were material to the controversy and went to the root of the matter. The evidence was found to be necessary for proper examination of the issues in dispute. In the interest of justice, the Tribunal admitted the additional evidence and held that the same required thorough verification at the level of the Assessing Officer. The Tribunal therefore set aside the disputed issues to the Assessing Officer for fresh decision after granting adequate opportunity of hearing to the assessee.

Conclusion: The additional evidence was admitted and the matter was remanded to the Assessing Officer for fresh adjudication in accordance with law.

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