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2025 Supreme(Online)(ITAT) 4824

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
SHRI S.RIFAUR RAHMAN, ACJ, SHRI CHALLA NAGENDRA PRASAD, J
Late Shri Brat Pal Singh Tyagi – Appellant
Versus
DCIT, Central Circle, Ghaziabad – Respondent


Advocates:
For the Appellants/Petitioners: Shri R.K. Garg
For the Respondents: Shri Ajay Kumar Arora

Table of Content
1. cross appeals overview. (Para 1 , 2)
2. cit(a) rejection of additional evidence. (Para 4 , 5)
3. assessee's appeal issues regarding assessment. (Para 7 , 8 , 9 , 10)
4. importance of corroborative evidence in admissions. (Para 14 , 15)
5. conclusive ruling on appeals. (Para 16)

ORDER

PER S.RIFAUR RAHMAN,ACCOUNTANT MEMBER :

1. The assessee and Revenue has filed cross appeals against the order of ld. Commissioner of Income Tax (Appeals)-33, Noida [“ld. CIT(A)”, for short] dated 24.07.2024 for AY 2018-19. The assessee has also filed appeal against the order of ld. CIT (A)-33, Noida dated 22.05.2024 for AY 2017-18.

2. Since the issues are common and the appeals are connected, therefore, the same are heard together and being disposed off by this common order.

3. First we take up assessee’s appeal for AY 2017-18 being ITA No.3348/Del/2024.

4. At the time of hearing, ld. AR of the assessee pressed hard on the ground that ld. CIT (A) has not admitted the additional evidences filed in the shape of affidavit which is fully covered under Rule 46A of the Income Tax Rules, 1961 but ld. CIT (A) rejected the same stating that there is no sufficient cause which prevented the assessee from

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