Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
Admission of additional evidence in appeal does not dispense with Rule 46A(3) compliance merely because the appellate authority invokes section 250(4). Where documents are produced for the first time in appeal and relied upon, the Assessing Officer must be confronted with them and given an opportunity to verify and comment. The Tribunal distinguished appellate enquiry powers from the separate procedure for admitting additional evidence, and held that they cannot be conflated to bypass the mandatory opportunity to the Assessing Officer. The deletion of the section 68 addition was therefore set aside on this limited ground, and the matter was remanded for fresh consideration after a remand report.
Admission of additional evidence in appeal does not dispense with Rule 46A(3) compliance merely because the appellate authority invokes section 250(4). Where documents are produced for the first time in appeal and relied upon, the Assessing Officer must be confronted with them and given an opportunity to verify and comment. The Tribunal distinguished appellate enquiry powers from the separate procedure for admitting additional evidence, and held that they cannot be conflated to bypass the mandatory opportunity to the Assessing Officer. The deletion of the section 68 addition was therefore set aside on this limited ground, and the matter was remanded for fresh consideration after a remand report.
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