CIT(A)’s Deletion of ₹2.32 Cr Addition u/s 68 Based on Evidence Admitted in Violation of Rule 46A:...

The Income Tax Appellate Tribunal (ITAT) has set aside a CITA's (Commissioner of Income Tax Appeals) deletion of a crore addition under Section 68, and remanded it to the AO, as the evidence was admitted in violation of Rule 46A. Rule 46A of the Income Tax Rules governs the admission of additional evidence at the appellate stage. The ITAT found that the CITA allowed new evidence without following proper procedure, potentially compromising fairness. By remanding, the tribunal ensures that the Assessing Officer re-evaluates the case, considering any new evidence only after due process and verification, upholding procedural integrity.