Additional evidence and adequate opportunity rejected where repeated appellate hearings were missed, with no substantial question of law found.

The assessee's claim of denial of adequate opportunity to produce evidence failed because the record showed repeated opportunities before the appellate authority, including a final fixed-date hearing, which the assessee did not attend. In that setting, the objection under Rule 29 of the Income-tax Rules, 1962, that additional evidence had been improperly ignored, was not accepted. The appellate findings were treated as flowing from the assessee's own default, and the Delhi HC found no substantial question of law warranting interference under section 260A of the Income-tax Act, 1961.

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Issues: Whether the assessee was denied adequate opportunity to produce evidence and whether the refusal to interfere under section 260A of the Income-tax Act, 1961 was justified.

Analysis: The record showed that the assessee was repeatedly granted opportunities before the appellate authority, including a final opportunity on a fixed date, but no appearance was made on that date. In those circumstances, the assessee could not successfully contend that its right to place additional evidence had been improperly ignored under Rule 29 of the Income-tax Rules, 1962. The concurrent findings of the appellate authorities were based on the assessee's own default, and no substantial question of law arose for interference in second appeal.

Conclusion: The issue was decided against the assessee and in favour of the Revenue.

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