ITAT Mumbai: Rule 46A Violation Fatal – CIT(A) Cannot Delete Additions Without AO Verification

ITO Vs Ashwin Popatlal Shah (ITAT Mumbai) ITAT Mumbai: Rule 46A Violation Fatal – CIT(A) Cannot Delete Additions Without AO Verification In this case, the ITAT Mumbai dealt with deletion of ₹2.01 crore alleged bogus purchase addition by the CIT(A), where the assessee had produced confirmations, invoices, and ITRs of suppliers during appellate proceedings. The Tribunal found a serious procedural lapse—the CIT(A) had relied on additional evidence not furnished before the AO and failed to follow mandatory Rule 46A procedure, i.e., no remand report or opportunity was given to the Assessing O...