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

Before the Commissioner (Appeals), Suresh Pillai wants to produce a bank confirmation that he never showed to the Assessing Officer. He says the Assessing Officer passed the order without giving him sufficient opportunity to adduce evidence relevant to a ground of appeal. Under Rule 192 of the Income-tax Rules, 2026, what is the position?

The evidence can be admitted because the order was made without sufficient opportunity to adduce evidence. The Commissioner (Appeals) must record reasons in writing, and cannot rely on the evidence unless the Assessing Officer gets a reasonable opportunity to examine it or rebut it.

  1. AThe evidence cannot be admitted in any circumstances
  2. BThe evidence can be admitted, with reasons recorded in writing, and the Assessing Officer must get a reasonable opportunity to examine it or rebut itCorrect
  3. CThe evidence can be admitted without recording reasons, as the appellant is aggrieved
  4. DThe evidence can be admitted only if the Assessing Officer consents in writing

Explanation

Rule 192(1)(d) permits additional evidence where the order was made without sufficient opportunity to adduce evidence. Rule 192(2) requires the reasons for admission to be recorded in writing. Rule 192(3) bars reliance on it unless the Assessing Officer has a reasonable opportunity to examine or rebut it. No consent of the Assessing Officer is required.

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