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The ITAT allowed the assessee's application under Rule 29 to admit additional evidence relating to the bona fide nature and agreed price of shares acquired in an off-market transaction. The tribunal acknowledged that the AO applied section 56(2)(x) deeming income based on the difference between the aggregate FMV and consideration paid, resulting in a substantial addition. Given the anti-abuse intent of section 56(2)(x) and the pending identical issue before the CIT(A) for other promoters, the ITAT emphasized the importance of evaluating the newly submitted evidence. Consequently, the matter was remanded to the CIT(A) for fresh adjudication on merits, ensuring the assessee is not prejudiced by earlier non-filing of material information, and to ascertain the correct valuation and applicability of section 56(2)(x).
The ITAT allowed the assessee's application under Rule 29 to admit additional evidence relating to the bona fide nature and agreed price of shares acquired in an off-market transaction. The tribunal acknowledged that the AO applied section 56(2)(x) deeming income based on the difference between the aggregate FMV and consideration paid, resulting in a substantial addition. Given the anti-abuse intent of section 56(2)(x) and the pending identical issue before the CIT(A) for other promoters, the ITAT emphasized the importance of evaluating the newly submitted evidence. Consequently, the matter was remanded to the CIT(A) for fresh adjudication on merits, ensuring the assessee is not prejudiced by earlier non-filing of material information, and to ascertain the correct valuation and applicability of section 56(2)(x).
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