CIT(A) Wrongly Refused Additional Evidence on Technical Ground: Matter Remanded for Fresh Decision

Suresh Chand Vs ITO (ITAT Delhi) The Assessee filed an appeal against the NFAC order dated 24.10.2024 confirming reassessment u/s 147 r.w.s.144 for AY 2014-15. There was a delay of 105 days, for which a condonation petition was filed. Tribunal found the reasons sufficient and condoned the delay. The core grievance was that the CIT(A)/NFAC rejected additional evidence merely because it was not accompanied by a formal Rule 46A petition. Tribunal noted that although the technical requirement was not fulfilled, the Assessee had submitted all material documents intended to substantiate claims on me...