Admission of Additional Evidence Valid as AO Had Full Opportunity: No Rule 46A Violation

ACIT Vs H.V. Infratex Ltd. (ITAT Ahmedabad) The Income Tax Appellate Tribunal (ITAT) Ahmedabad dismissed the revenue’s appeal against the Commissioner of Income Tax (Appeals) [CIT(A)]’s order, which had deleted an ad-hoc disallowance of Rs. 5,92,53,633 made by the Assessing Officer (AO) under Section 37 of the Income Tax Act. The AO had disallowed 25% of the assessee’s total other expenses, citing a lack of supporting documents. The assessee, H.V. Infratex Ltd., had provided additional evidence during the appellate proceedings, including ledgers and invoices, which the CIT(A)...