Admission of additional evidence in appeal does not dispense...

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.