https://www.taxtmi.com/caselaws?id=467494 Natural justice required the assessee and deponents to receive a reasonable opportunity to explain, verify, or be cross-examined on affidavits and ledger accounts submitted as additional evidence under Rule 46A. Although the CIT(A) admitted the evidence, the Assessing Officer's remand report criticised it without conducting enquiry or summoning the assessee or deponents, despite authority to do so. Defects concerning identity, supporting employment or salary records, and alleged subsequent preparation could be relied upon only after such participation. The penalty upheld under Sections 271E and 269T was therefore set aside for denial of a fair hearing in the remand process, and the appeal succeeded. en-us Thu, 15 May 2025 00:00:00 +0530 Thu, 19 Mar 2026 14:44:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467494 Natural justice required the assessee and deponents to receive a reasonable opportunity to explain, verify, or be cross-examined on affidavits and ledger accounts submitted as additional evidence under Rule 46A. Although the CIT(A) admitted the evidence, the Assessing Officer's remand report criticised it without conducting enquiry or summoning the assessee or deponents, despite authority to do so. Defects concerning identity, supporting employment or salary records, and alleged subsequent preparation could be relied upon only after such participation. The penalty upheld under Sections 271E and 269T was therefore set aside for denial of a fair hearing in the remand process, and the appeal succeeded. Case-Laws Income Tax Thu, 15 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467494