https://www.taxtmi.com/caselaws?id=427830 Concurrent factual findings on deletion of additions and admission of additional evidence under Rule 46A were not open to interference in second appeal absent perversity or contrary material. The lower authorities found no specific show-cause notice for the disputed additions, accepted the assessee's reasonable cause for earlier non-production of evidence, and held that the share capital, share premium, unsecured loans and unexplained investment items were either carried forward from earlier years or supported by banking records, books and documentary evidence. Because the dispute turned on appreciation of evidence rather than any substantial legal issue, no substantial question of law arose and the Revenue's challenge failed. en-us Wed, 14 Sep 2022 00:00:00 +0530 Fri, 16 Sep 2022 17:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=427830 Concurrent factual findings on deletion of additions and admission of additional evidence under Rule 46A were not open to interference in second appeal absent perversity or contrary material. The lower authorities found no specific show-cause notice for the disputed additions, accepted the assessee's reasonable cause for earlier non-production of evidence, and held that the share capital, share premium, unsecured loans and unexplained investment items were either carried forward from earlier years or supported by banking records, books and documentary evidence. Because the dispute turned on appreciation of evidence rather than any substantial legal issue, no substantial question of law arose and the Revenue's challenge failed. Case-Laws Income Tax Wed, 14 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=427830