Admission of additional evidence permitted, with taxpayer claims remitted for fresh assessment after a reasonable hearing opportunity.

Admission of additional evidence was considered where the documents were relevant to determining the taxpayer's claims and the explanation for their earlier non-production was accepted. As the Revenue did not seriously oppose admission or fresh examination, the evidence was admitted. The claims and remaining contentions were remitted to the Assessing Officer for fresh adjudication after giving the taxpayer a reasonable opportunity of being heard.

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Issues: Whether additional evidence tendered by the assessee should be admitted for adjudication of its claims.

Analysis: The additional documents were found relevant to determining the admissibility of the claims, and the stated inability to produce them earlier was accepted. The Revenue did not seriously oppose their admission or a fresh examination by the Assessing Officer. The remaining contentions were kept open for consideration in the fresh proceedings.

Conclusion: The additional evidence was admitted and the matter was restored to the Assessing Officer for fresh adjudication after reasonable opportunity to the assessee.

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