Admissibility of documentary evidence at the appellate stage and...

Admissibility of documentary evidence at the appellate stage and treatment of unexplained investment are addressed. The article explains that an appellate authority has plenary powers coextensive with the assessing officer to examine and admit documentary material, and where documents are self explanatory and go to the root of the matter the appellate authority may admit and rely on them even if produced first on appeal; non compliance with the remand/report procedure did not vitiate the order. On merits, primary documents (loan sanction letter, sale agreement, bank statements) satisfactorily explained the source of investment in jointly acquired properties, warranting deletion of the addition as unexplained investment.