Additional evidence and remand in a Black Money Act dispute, with fresh adjudication ordered after further hearing.

Additional evidence was admitted under Rule 29 of the Income Tax (Appellate Tribunal) Rules, 1963 in a Black Money Act dispute where the earlier orders rested substantially on non-compliance and absence of supporting material. Because the assessee stated that relevant documents had since been obtained, and justice required a proper opportunity to place them on record, the matter was restored to the Commissioner for fresh adjudication. The Commissioner must reconsider the issue after examining the additional evidence and granting the assessee a reasonable opportunity of hearing.

---

---

Issues: Whether the matter should be remanded to the Commissioner for fresh adjudication after admission of additional evidence filed by the assessee.

Analysis: The appeal arose from an addition made under the Black Money Act and sustained by the Commissioner on the basis of non-compliance and absence of supporting material. The assessee sought admission of additional evidence before the Tribunal under Rule 29 of the Income Tax (Appellate Tribunal) Rules, 1963, contending that relevant documents had now been procured. As the assessment and first appellate orders were founded substantially on the lack of evidence, and the interests of justice required a proper opportunity to place material on record, the Tribunal found it appropriate to restore the matter for fresh decision after giving the assessee a reasonable opportunity of hearing.

Conclusion: The matter was remanded to the Commissioner for fresh adjudication after considering the additional evidence and granting due opportunity to the assessee.

---