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CA Final · Direct Tax Laws & International Taxation · Appeals and Revision

Anita, an assessee, was not allowed to produce a lease deed before the Assessing Officer because the officer gave her no sufficient opportunity to adduce evidence relevant to a ground of appeal. She now wishes to produce it before the Commissioner (Appeals). Under Rule 192 of the Income-tax Rules, 2026, what is the position?

The lease deed can be admitted, because Rule 192(1)(d) covers an order made without sufficient opportunity to adduce evidence. The Commissioner (Appeals) must record reasons in writing, and the Assessing Officer must be given a reasonable opportunity to examine or rebut the evidence.

  1. AIt is barred, since only evidence produced before the Assessing Officer can be used
  2. BIt can be admitted, but only if the Commissioner (Appeals) records reasons in writing and the Assessing Officer gets a reasonable opportunity to examine or rebut itCorrect
  3. CIt can be admitted without any further step
  4. DIt can be admitted only with the Assessing Officer's consent

Explanation

Rule 192(1)(d) permits fresh evidence where the Assessing Officer made the order without giving sufficient opportunity. Under rule 192(2) reasons for admission must be recorded in writing, and under rule 192(3) the Assessing Officer must get a reasonable opportunity to examine or rebut it. The total bar option ignores the exceptions.

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