Acceptance of additional evidence when AO has given sufficient Opportunity to Assessee

Rule 46A – Additional evidence should not be admitted by CIT(A) if A.O. has given sufficient Opportunity to Assessee We have perused form no. 35 i.e. memo of appeal filed by the assessee before ld. CIT(Appeals). In the grounds raised, there is neither any ground nor whisper about not providing sufficient opportunity by AO while framing the assessment. It is further evidenced from the fact that the assessment proceedings commenced on 26- 9-2008 and assessment order has been passed on 10-11-2009 indicating that sufficient time was given to assessee for compliance. Therefore, there is no ju...