https://www.taxtmi.com/caselaws?id=217253 Additional evidence cannot be admitted or relied upon at the appellate stage unless the conditions of Rule 46A are satisfied, reasons for admission are recorded, and the Assessing Officer is given a reasonable opportunity to examine and rebut the material. Where the Commissioner (Appeals) accepts fresh material without following this procedure, the action is contrary to law and breaches natural justice. In such a situation, the proper course is remand for fresh adjudication, with the assessment issues examined de novo after hearing the assessee and considering the material already placed before the appellate authority. en-us Mon, 07 May 2012 00:00:00 +0530 Tue, 09 Oct 2012 07:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=217253 Additional evidence cannot be admitted or relied upon at the appellate stage unless the conditions of Rule 46A are satisfied, reasons for admission are recorded, and the Assessing Officer is given a reasonable opportunity to examine and rebut the material. Where the Commissioner (Appeals) accepts fresh material without following this procedure, the action is contrary to law and breaches natural justice. In such a situation, the proper course is remand for fresh adjudication, with the assessment issues examined de novo after hearing the assessee and considering the material already placed before the appellate authority. Case-Laws Income Tax Mon, 07 May 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=217253