Additional evidence under Rule 29 is limited to Tribunal need or substantial cause, not to cure assessee negligence.

Rule 29 of the Income-tax (Appellate Tribunal) Rules, 1963 permits additional evidence only when the Tribunal itself requires it to enable a just decision, or when some other substantial cause tied to the interests of justice is shown, or when evidence was wrongly denied at the assessment stage. Where an assessee had repeated opportunities before the Wealth-tax Officer and the Appellate Assistant Commissioner but produced no evidence, and the assessments were made ex parte because of that omission, the legal representative cannot use the second appeal stage to cure the assessee's negligence. Additional evidence is to be admitted cautiously and sparingly, and not to reward remissness or gross negligence.

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Issues: Whether the legal representative of a deceased assessee could be permitted to produce additional evidence before the Tribunal under rule 29 of the Income-tax (Appellate Tribunal) Rules, 1963, after ex parte wealth-tax assessments had been made and confirmed by the lower authorities.

Analysis: Rule 29 permits additional evidence only where the Tribunal requires it to enable it to pass orders or where there is any other substantial cause, or where the Income-tax Officer decided the case without giving sufficient opportunity to the assessee to adduce evidence. The assessee had been given repeated opportunities before the Wealth-tax Officer and the Appellate Assistant Commissioner but produced no evidence, and the assessments were made ex parte on that account. The legal representative could not improve the assessee's position merely by coming on record at the second appeal stage. The expression "for any other substantial cause" was read as referring to a requirement of the Tribunal itself, and the discretion to admit additional evidence had to be exercised cautiously and sparingly. A party guilty of remissness and gross negligence was not entitled to such indulgence.

Conclusion: The request to adduce additional evidence was rightly refused, and the question was answered against the assessee.

Ratio Decidendi: Additional evidence under rule 29 of the Income-tax (Appellate Tribunal) Rules, 1963, can be admitted only when the Tribunal itself requires it or when a substantial cause, tied to the needs of justice, is shown; it cannot be used to cure an assessee's negligence or omissions after repeated opportunities to lead evidence have been missed.

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