Fresh Documents at Appeal Stage Led to Remand Under Rule 46A

ITO Vs Ashutosh Gupta (ITAT Dehradun) Rule 46A Can’t Be Bypassed: Dehradun ITAT Sets Aside CIT(A) Relief Granted on Fresh Evidence Dehradun Bench of the ITAT, in ITO vs Ashutosh Gupta (ITA No. 198/DDN/2025, AY 2023-24, order dated 19.12.2025), set aside the order of CIT(A)/NFAC which had partly deleted a massive addition of ₹6.39 crore made u/s 143(3) r.w.s. 144B. The Tribunal noted that during appellate proceedings, the Assessee had produced fresh documents for the first time before CIT(A) without filing any application u/s Rule 46A of the Income-tax Rules, 1962, and such documents were a...