https://www.taxtmi.com/caselaws?id=790635 Rule 46A permits additional evidence at the appellate stage only in exceptional circumstances and requires the Commissioner (Appeals) to record written reasons showing that those conditions are met. It also obliges that the Assessing Officer be given a reasonable opportunity to examine the fresh material and produce rebuttal evidence, as part of natural justice. On the facts stated, no speaking order admitting the additional evidence was shown and no effective opportunity to rebut it was established. The admission and use of the evidence were therefore held invalid, the Tribunal's affirmation was unsustainable, and the matter was remanded to the Commissioner (Appeals) for fresh consideration in accordance with law. en-us Thu, 16 Apr 2026 00:00:00 +0530 Tue, 28 Apr 2026 07:29:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790635 Rule 46A permits additional evidence at the appellate stage only in exceptional circumstances and requires the Commissioner (Appeals) to record written reasons showing that those conditions are met. It also obliges that the Assessing Officer be given a reasonable opportunity to examine the fresh material and produce rebuttal evidence, as part of natural justice. On the facts stated, no speaking order admitting the additional evidence was shown and no effective opportunity to rebut it was established. The admission and use of the evidence were therefore held invalid, the Tribunal's affirmation was unsustainable, and the matter was remanded to the Commissioner (Appeals) for fresh consideration in accordance with law. Case-Laws Income Tax Thu, 16 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790635