Fresh evidence in first appeal may be examined under coterminous appellate powers, with remand verification where factual disputes remain unresolved.

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....First appellate authorities with powers coterminous with the Assessing Officer may examine fresh evidence filed in appeal and may obtain a remand report where verification is required. Rejecting fresh purchase, vendor-balance, sales, expense, and tax-deduction details solely because complete material was not furnished during assessment leaves factual disputes unverified. Additions and disallowances founded on such discrepancies require fresh verification through de novo adjudication, with an adequate hearing opportunity and taxpayer cooperation.....