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Judgment
This assessee’s appeal for Assessment Year 2020-21 arises against the C IT(A)23, Delhi’s DIN & order No. ITBA/APL/ S/250/2025-26/1082457246(1) dated 11.11.2025, in proceedings u/ s 147 of the Income Tax Act, 1961 (in short “the Act”).
Heard both the p arties at length. Case file perused.
It emerges during the cour se of hearing that the learned Assessing Office r had framed his impugned assessment on 30.03.2024 inter alia making the twin additions of unsecured loans treated as unexplained cash cred its, bogus expenditure and disallowance of interest; involving varying sums, which stand upheld in the lower appellate discussion.
That being the case, learned counse l has invited the tribunal’s attention to page 3 para 6 in the CIT(A)’s lower appellate discussion wherein the assessee appears to have filed it’s applicatio n under Rule 46A of the Income Tax Rules seeking to admit it’s additio nal evidence w hich stood summarily rejected. The Re venue could hardly dispute that there is not even a clear indication in the learned CIT(A)’s lower appellate discussion as to the assessee’s additional evidence could not be held admissible for any specific reason.
I accordingly deem it appropriate to restore the assessee’s instant appeal w ith a clear cut direction to the CIT(A) to ad mit the assessee’s additional evidence and get necessary facts verified as per law in very terms, within three effective opportunities subject to a rider that the assessee shall p lead and prove the case at it’s ow n risk and responsibility, in consequential proceedings. Ordered according ly.
This assessee’s appeal is allowed for statistical purposes.