https://www.taxtmi.com/caselaws?id=343315 Rule 46A was not violated because the record did not show that the assessee introduced fresh material before the first appellate authority, and the materials considered were already part of the assessment record. The unsigned note relied on by the Revenue was not linked to the assessee or the developer's office, while contemporaneous memoranda of understanding and related documents supported the recorded booking rate and did not show any payment beyond disclosed consideration. On those facts, the factual foundation for invoking unexplained expenditure treatment did not survive, so the addition under Section 69C could not be sustained and no substantial question of law arose from the concurrent findings. en-us Tue, 25 Apr 2017 00:00:00 +0530 Tue, 23 May 2017 07:52:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=343315 Rule 46A was not violated because the record did not show that the assessee introduced fresh material before the first appellate authority, and the materials considered were already part of the assessment record. The unsigned note relied on by the Revenue was not linked to the assessee or the developer's office, while contemporaneous memoranda of understanding and related documents supported the recorded booking rate and did not show any payment beyond disclosed consideration. On those facts, the factual foundation for invoking unexplained expenditure treatment did not survive, so the addition under Section 69C could not be sustained and no substantial question of law arose from the concurrent findings. Case-Laws Income Tax Tue, 25 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=343315