https://www.taxtmi.com/caselaws?id=787465 Admission of fresh documentary evidence before the Commissioner (Appeals) under Rule 46A without affording the Assessing Officer a reasonable opportunity to examine or to produce rebuttal evidence breaches Rule 46A(3); the appellate authority must also record reasons for admission. The Tribunal applied binding precedent that treats Rule 46A(3) as mandatory and held that reliance on such evidence in the absence of the AO's opportunity vitiates the appellate order; the CIT(A)'s order was set aside and the matter remitted for fresh adjudication after Rule 46A compliance. en-us Fri, 30 Jan 2026 00:00:00 +0530 Fri, 06 Mar 2026 08:30:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787465 Admission of fresh documentary evidence before the Commissioner (Appeals) under Rule 46A without affording the Assessing Officer a reasonable opportunity to examine or to produce rebuttal evidence breaches Rule 46A(3); the appellate authority must also record reasons for admission. The Tribunal applied binding precedent that treats Rule 46A(3) as mandatory and held that reliance on such evidence in the absence of the AO's opportunity vitiates the appellate order; the CIT(A)'s order was set aside and the matter remitted for fresh adjudication after Rule 46A compliance. Case-Laws Income Tax Fri, 30 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787465