https://www.taxtmi.com/caselaws?id=383230 Delay of 1159 days in filing the Revenue's appeal was condoned because the departmental explanation of cadre restructuring, file movement and multiple charges was accepted as showing reasonable cause. On the merits, the first appellate authority's reliance on additional evidence without giving the Assessing Officer an opportunity to examine it was held to violate Rule 46A. As the interest-rate comparison, application of SBI PLR, and treaty-based tax treatment depended on that material, the matter was remanded to the Assessing Officer/TPO for fresh consideration, and the order on merits was set aside. en-us Wed, 12 Jun 2019 00:00:00 +0530 Thu, 18 Jul 2019 11:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=383230 Delay of 1159 days in filing the Revenue's appeal was condoned because the departmental explanation of cadre restructuring, file movement and multiple charges was accepted as showing reasonable cause. On the merits, the first appellate authority's reliance on additional evidence without giving the Assessing Officer an opportunity to examine it was held to violate Rule 46A. As the interest-rate comparison, application of SBI PLR, and treaty-based tax treatment depended on that material, the matter was remanded to the Assessing Officer/TPO for fresh consideration, and the order on merits was set aside. Case-Laws Income Tax Wed, 12 Jun 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=383230