circumstances (a), (b), (c) & (d) of sub-rule (1) of provided under Rule 46A
and found that the appellant does not satisfy ... that the
appellant has not satisfied the conditions in sub rules under Rule 46A.
It must be mentioned here the decision given
admitting additional evidence in
contravention of provisions of Rule 46A of
the Income-tax Rules, 1961.
ITAT-Jabalpur Page ... from contract receipts admitting additional
evidence in contravention of provisions of
Rule 46A of the Income-tax Rules, 1961. On
the facts
learned
CIT(A) has erred in allowing additional evidence under rule 46A whereas
the assessee's case is not covered by the exceptions provided ... under rule 46A
of the I.T. Rules.
4. On the facts and in the circumstances of the case and in law, the
learned
circumstances (a), (b), (c) & (d) of sub-rule (1) of provided under Rule 46A
and found that the appellant does not satisfy ... that the
appellant has not satisfied the conditions in sub rules under Rule 46A.
It must be mentioned here the decision given
under section 271 .]
16. Reading section 250(4) and sub-rule 4 of Rule 46A in order to give a
harmonious interpretation ... officer. This observation takes care
of clause (c) of sub-rule (1) of Rule 46A. The observation of the CIT (A)
also takes care
without verification, requirement of Rule
46(3) were not satisfied?
In the instant case there was violation of Rule 46A(3) on
the part ... Rule 46A of the
income tax Rules 1962. Therefore an order passed in violation of
Rule 46A deserves to be set aside and more
your goodself to kindly admit the above as additional
evidence under Rule 46A of the Income Tax Rules)."
17. The Ld. Commissioner, though considered ... documents including TDS challans in the form of additional evidence
under Rule 46A of the Income Tax Rules, 1962 (in short
'Rules').Somehow
without verification, requirement of Rule
46(3) were not satisfied?
In the instant case there was violation of Rule 46A(3) on
the part ... Rule 46A of the
income tax Rules 1962. Therefore an order passed in violation of
Rule 46A deserves to be set aside and more
same
should be admitted as additional document under the provision of Rule 46A of
Income tax rule 1962.
7.2 Likewise, the credit of unsecured ... assessee as these
evidences were not as per the rule prescribed under rule 46A of income tax. Thus
the learned AR pleaded before
46A of the Rules as such production of
additional evidence was not covered under clause (a) to (d) of Rule 46A and
no reasons have ... violation of Rule 46A of the Rules as not covered under clause (a) to (d) of
rule 46A and no reasons have been recorded
