Additional evidence in section 68 matters requires remand when the Assessing Officer was not given a chance to verify it.

Where the first appellate authority admits additional evidence that was not examined by the Assessing Officer, and that material goes to the root of the section 68 dispute, the proper course is remand for fresh adjudication. The Tribunal held that the Assessing Officer must be given an opportunity to verify the evidence and examine the transactions afresh, with both sides heard in accordance with law. The additions were therefore restored to the Assessing Officer for de novo consideration, and no final view was taken on the merits of the additions.

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Issues: Whether the additions made under section 68 on the basis of additional evidence admitted by the first appellate authority without remand report from the Assessing Officer required remand for fresh adjudication.

Analysis: The additions arose from the first appellate authority's acceptance of material that had not been examined by the Assessing Officer. Since the material went to the root of the controversy and the Assessing Officer had not been given an opportunity to verify it, the proper course was to restore the matter for fresh consideration. The Tribunal also directed that the Assessing Officer examine the transactions afresh on the basis of all evidence, including evidence produced for the first time before the first appellate authority, and decide the matter in accordance with law after affording opportunity of hearing.

Conclusion: The issue was remanded to the Assessing Officer for de novo consideration, and the additions were not finally sustained or deleted on merits.

Ratio Decidendi: Where the first appellate authority relies on additional evidence without obtaining the Assessing Officer's examination of that material, remand for fresh adjudication is warranted.

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