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    <title>2025 (4) TMI 901 - ITAT JAIPUR</title>
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    <description>The ITAT Jaipur dismissed the revenue&#039;s appeal challenging CIT(A)&#039;s decision to admit additional evidence under Rule 46A without providing AO adequate opportunity for rebuttal. The tribunal held that CIT(A) has co-terminus powers to admit evidence, and AO remained silent despite multiple reminders during the six-year pending appeal period. Regarding disallowance of purchase and development expenses, the tribunal found that the assessee had submitted sufficient documentation including TDS certificates, ITR acknowledgments, bank statements, and transaction details through banking channels. The tribunal noted that contractors responded to summons by post with required details, and non-personal appearance doesn&#039;t invalidate genuine transactions. The ITAT upheld CIT(A)&#039;s finding that expenses were legitimate, dismissing all revenue grounds.</description>
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    <pubDate>Thu, 30 Jan 2025 00:00:00 +0530</pubDate>
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      <title>2025 (4) TMI 901 - ITAT JAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=768987</link>
      <description>The ITAT Jaipur dismissed the revenue&#039;s appeal challenging CIT(A)&#039;s decision to admit additional evidence under Rule 46A without providing AO adequate opportunity for rebuttal. The tribunal held that CIT(A) has co-terminus powers to admit evidence, and AO remained silent despite multiple reminders during the six-year pending appeal period. Regarding disallowance of purchase and development expenses, the tribunal found that the assessee had submitted sufficient documentation including TDS certificates, ITR acknowledgments, bank statements, and transaction details through banking channels. The tribunal noted that contractors responded to summons by post with required details, and non-personal appearance doesn&#039;t invalidate genuine transactions. The ITAT upheld CIT(A)&#039;s finding that expenses were legitimate, dismissing all revenue grounds.</description>
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      <pubDate>Thu, 30 Jan 2025 00:00:00 +0530</pubDate>
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