VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawConcepts › Rule 46A: getting new evidence in, and the remand report you cannot skip

Rule 46A: getting new evidence in, and the remand report you cannot skip

How do I get evidence before the CIT(A) that I never filed with the Assessing Officer?

How do I get evidence before the CIT(A) that I never filed with the Assessing Officer?

Rule 46A(1) allows additional evidence only through four gateways, and Rule 46A(3) forbids the CIT(A) from taking that evidence into account unless the Assessing Officer has been given a reasonable opportunity to examine it and rebut it. Rule 46A(4) preserves the CIT(A)'s own power to call for evidence, and the Bombay High Court has held that the rule does not fetter his powers under section 250(4) and (5).

This is an explainer, not a judgment. It states the law in our own words, which is exactly why it needs checking. Everything below was written from the sources listed at the foot of this page, and no chartered accountant has yet signed it off. Read the source before you rely on it in a reply or an appeal.

The four gateways in Rule 46A(1) are: the Assessing Officer refused to admit evidence which ought to have been admitted; the appellant was prevented by sufficient cause from producing evidence he was called upon to produce; the appellant was prevented by sufficient cause from producing evidence relevant to any ground of appeal; or the Assessing Officer made the order without giving the appellant sufficient opportunity to adduce evidence. Rule 46A(2) requires the Commissioner (Appeals) to record his reasons for admitting the evidence. Rule 46A(3) is the provision that decides most appeals: additional evidence shall not be taken into account unless the Assessing Officer has been allowed a reasonable opportunity to examine it or to cross-examine the witness. In practice that means a remand report. An order that admits fresh evidence behind the Assessing Officer's back is liable to be set aside and the matter restored - which is precisely the outcome the assessee was trying to avoid. Rule 46A(4) saves the appellate authority's independent power to direct production of a document or examination of a witness to dispose of the appeal, and the Bombay High Court in Smt. Prabhavati S. Shah held that while Rule 46A fetters the assessee's right to produce evidence, it does not restrain the Commissioner (Appeals) from acting under section 250(4) or 250(5) where the evidence appears necessary to examine the claim. The two routes should be pleaded together: the Rule 46A application as the primary route, the section 250(4) direction as the alternative. The common errors are filing the documents in the paperbook without any Rule 46A application, failing to explain sufficient cause on affidavit, and - fatally for the assessee who wins below - not insisting that a remand report be called for.

What to do

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