AI Structured Summary
Not yet generated for this judgment
Judgment
This assessee’s appeal for Assessment Year 2023-24, arises against the C IT(A)/NFAC, Delhi’s DIN & order No. ITBA/NFAC/S/250/2025-26/1083843782(1), dated 18.12.2025 in proceedings u/s 143(3) r.w.s. 144B of the Income Tax Act, 1961 (in short “ the Act”).
Case called tw ice. None appears at the asse ssee’s behest. I accordingly proceeded ex parte.
It is next noticed with the able assistance coming from the Revenue side that the learned assessing authority had framed t h its assessment dated 9 March, 2025 in the assessee’s case , inter alia, making Section 68 unexplained cash credits addition of Rs.14,96,711/- followed by disallowance of depreciation of Rs.2 ,46,455/- which stand up held in the lower appellate discussion.
That being the case , the Revenue co uld hardly dispute that the assessee had opted to file its application seeking admission of additional evidence under Rule 46A of the Income Tax Rules, 1962 before the C IT( A) in the lo wer appellate proceedings which has been summarily rejected witho ut even discussing as to whether the same was a relevant one going to the root of the matter or not. It is thus deemed appropriate in the larger interest o f justice to direct the learned CIT(A)/NFAC to admit the aforementioned evidence as per law subject to a rider that the assessee shall plead and prove the same on its own risk and responsibility within three effective opportunities of hear ing. All other remaining issues are kept open.
The assessee’s appeal is allowed for statistical purposes.