2026 (1) TMI 1252

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.... CIT (A)- 3. Noida has erred in admitting additional evidence submitted by the assessee during appellate stage in contravention to the letter and spirit of Rule 46A of the Income Tax Rule, 1962 as the assessee failed to prove that it was prevented by sufficient cause from producing the same before the Assessing Officer 2. Whether on facts and circumstances of the case and in law, Ld. CIT(A)-3. Noida has erred in deleting the addition of Rs. 5,10,76,762/-made u/s 68 of the Act on account of unexplained credit in the books of accounts of the assessee, without appreciating the facts that the assessee during the course of assessment proceedings failed to discharge the onus of creditworthiness and genuineness of the alleged loans. ....

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....r on the basis of documents produced before him. The ld. counsel for the assessee further submitted that the additional evidences filed before the ld. CIT(A) were confronted to the Assessing Officer who, in his remand report, remained silent on the relevance of the evidences filed before the ld. CIT(A) supporting his contentions. 5. Per contra, the ld. DR relied on the orders of the Assessing Officer. 6. We have heard the rival submissions and have perused the relevant material on record. We find that the additional evidences submitted before the ld. CIT(A) have been duly confronted to the Assessing Officer by the CIT(A) vide his letter dated 12.07.2024. In his remand report, the AO vide his report dated 11.11.2024, contested the acti....