Appellate evidence not confronted to the Assessing Officer justified remand for fresh verification and reconsideration.

Documentary evidence first filed at the appellate stage, without being confronted to the Assessing Officer, required fresh verification before any deletion of the addition could stand. The appellate authority's acceptance of such material without prior examination by the Assessing Officer was treated as improper on the facts, because the correctness and veracity of the documents remained untested. The matter was therefore restored for de novo adjudication by the Assessing Officer, with a meaningful opportunity of hearing to the assessee, and the appellate relief was set aside in favour of the Revenue.

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Issues: Whether the order of the first appellate authority deleting the addition based on documentary evidence filed for the first time without confronting the Assessing Officer called for interference and remand for fresh examination.

Analysis: The documentary evidence accepted at the appellate stage had not been confronted to the Assessing Officer. In such circumstances, the correctness and veracity of those documents required fresh scrutiny by the Assessing Officer. The matter was therefore fit to be restored for de novo consideration, with a meaningful opportunity of hearing to the assessee.

Conclusion: The issue was decided in favour of the Revenue by setting aside the appellate relief and remanding the matter to the Assessing Officer for fresh adjudication.

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