Additional evidence under Rule 29 admitted as essential certificates were remanded for verification and fresh adjudication.

Admission of additional evidence under Rule 29 was justified because the tax residency certificate and the certificate on residence and absence of permanent establishment were treated as essential to resolve the disputed disallowance. The Tribunal held that these materials required examination at the assessment stage in the interests of justice, and the assessee was entitled to a full opportunity of hearing. The application was therefore accepted, and the issue was restored to the Assessing Officer for verification of the documents and fresh adjudication in accordance with law.

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Issues: Whether the assessee's application under Rule 29 of the Income Tax (Appellate Tribunal) Rules, 1963 for admission of additional evidence was to be ed, and whether the matter was required to be sent back to the Assessing Officer for fresh examination of the disputed disallowance.

Analysis: The additional documents, namely the tax residency certificate and the certificate regarding residence and absence of permanent establishment, were found to be essential for deciding the dispute. The Tribunal held that these documents required thorough examination at the assessment stage and that their admission was justified in the interest of justice. It therefore accepted the application for additional evidence and restored the issue to the Assessing Officer for verification of those materials and for fresh adjudication after granting the assessee a full opportunity of hearing.

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

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