https://www.taxtmi.com/caselaws?id=469445 Admission of additional evidence at the first appellate stage must comply with Rule 46A, including the prescribed procedure and an opportunity to the Assessing Officer, even though section 251 empowers the appellate authority to confirm, reduce, enhance or annul an assessment. Where the assessee changes its stand between assessment and appeal and the record does not show due compliance with Rule 46A, appellate relief is vulnerable to interference. The appellate order was set aside and the matter restored for fresh adjudication, with remand directed for proper examination of the assessee's statement, its retraction, the employer relationship, business results, and the genuineness of the additions and claims. en-us Thu, 06 Mar 2025 00:00:00 +0530 Wed, 17 Jun 2026 19:02:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469445 Admission of additional evidence at the first appellate stage must comply with Rule 46A, including the prescribed procedure and an opportunity to the Assessing Officer, even though section 251 empowers the appellate authority to confirm, reduce, enhance or annul an assessment. Where the assessee changes its stand between assessment and appeal and the record does not show due compliance with Rule 46A, appellate relief is vulnerable to interference. The appellate order was set aside and the matter restored for fresh adjudication, with remand directed for proper examination of the assessee's statement, its retraction, the employer relationship, business results, and the genuineness of the additions and claims. Case-Laws Income Tax Thu, 06 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469445