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HC allowed the appeal, setting aside ITAT's order rejecting additional evidence under Rule 29. The court found ITAT committed a legal error by summarily dismissing the application without evaluating whether the documents were necessary for just and proper disposal of the appeal. The ruling emphasized that ITAT failed to consider the Supreme Court's established parameters for admitting additional evidence, particularly when such evidence was not previously presented before the Assessing Officer or Commissioner of Income Tax (Appeals). Consequently, the HC remanded the matter for fresh consideration, directing a comprehensive review of the additional documentary evidence.
HC allowed the appeal, setting aside ITAT's order rejecting additional evidence under Rule 29. The court found ITAT committed a legal error by summarily dismissing the application without evaluating whether the documents were necessary for just and proper disposal of the appeal. The ruling emphasized that ITAT failed to consider the Supreme Court's established parameters for admitting additional evidence, particularly when such evidence was not previously presented before the Assessing Officer or Commissioner of Income Tax (Appeals). Consequently, the HC remanded the matter for fresh consideration, directing a comprehensive review of the additional documentary evidence.
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