Appellate power to receive additional evidence supports remand for verification in a Section 10A exemption claim.

An appellate authority may receive additional evidence relevant to an exemption claim and remand the matter for verification when the document was not produced at assessment stage, because its co-extensive appellate power permits application of the principle underlying Order 41 Rule 27 CPC. In this Section 10A dispute, the certificate produced before the appellate stage could be examined for genuineness and veracity through remand, and that exercise was treated as lawful. The assessee's objection failed and the Revenue's challenge was rejected, with the impugned order affirmed.

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Issues: Whether the appellate authority could receive additional evidence, remand the matter for verification of the certificate, and allow the assessee's claim for exemption under Section 10A of the Income-tax Act, 1961.

Analysis: The assessee's supporting certificate was not produced at the assessment stage, but was produced before the appellate authority. The appellate authority was held to have co-extensive power with the Assessing Officer and to be entitled to apply the principle underlying Order 41 Rule 27 of the Code of Civil Procedure, 1908 for receiving additional evidence. The receipt of the document and remand of the matter for examination of its genuineness and veracity was treated as a lawful exercise of power. The Tribunal's stray observations in two paragraphs were regarded as unnecessary and were treated as deleted, since the core issue had already been decided.

Conclusion: The appellate authority was justified in receiving the additional certificate and remanding the matter for verification; the assessee's objection failed and the Revenue's challenge was rejected.

Final Conclusion: The impugned order was affirmed and the appeal was dismissed.

Ratio Decidendi: An appellate authority may receive additional evidence and remand the matter for verification where the document is relevant to the claim and the exercise is a lawful use of its co-extensive appellate power.

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