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    <title>2022 (11) TMI 1591 - ITAT DELHI</title>
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    <description>The appellate authority could not admit and rely on additional evidence without first confronting it to the Assessing Officer and giving an opportunity to examine or rebut it under Rule 46A(3). A sale deed was accepted as additional evidence and used to grant exemption under section 54, but the material was not shown to have been placed before the Assessing Officer. Because the mandatory procedural safeguard was not followed, the relief based on that evidence could not be sustained and the matter required fresh adjudication after both sides were heard.</description>
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      <description>The appellate authority could not admit and rely on additional evidence without first confronting it to the Assessing Officer and giving an opportunity to examine or rebut it under Rule 46A(3). A sale deed was accepted as additional evidence and used to grant exemption under section 54, but the material was not shown to have been placed before the Assessing Officer. Because the mandatory procedural safeguard was not followed, the relief based on that evidence could not be sustained and the matter required fresh adjudication after both sides were heard.</description>
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