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    <title>2025 (6) TMI 1911 - ITAT COCHIN</title>
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    <description>Documentary evidence first filed at the appellate stage, without being confronted to the Assessing Officer, required fresh verification before any deletion of the addition could stand. The appellate authority&#039;s acceptance of such material without prior examination by the Assessing Officer was treated as improper on the facts, because the correctness and veracity of the documents remained untested. The matter was therefore restored for de novo adjudication by the Assessing Officer, with a meaningful opportunity of hearing to the assessee, and the appellate relief was set aside in favour of the Revenue.</description>
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      <description>Documentary evidence first filed at the appellate stage, without being confronted to the Assessing Officer, required fresh verification before any deletion of the addition could stand. The appellate authority&#039;s acceptance of such material without prior examination by the Assessing Officer was treated as improper on the facts, because the correctness and veracity of the documents remained untested. The matter was therefore restored for de novo adjudication by the Assessing Officer, with a meaningful opportunity of hearing to the assessee, and the appellate relief was set aside in favour of the Revenue.</description>
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