Dy. CIT v. Reliance Industries Ltd. (2026) 310 Taxman 406 (SC) Dy. CIT v. Reliance Industries Ltd. (2026) 310 Taxman 488 (SC) Editorial: Reliance Industries Ltd v. P.L.Roongta (2025) 171 taxmann.com 467/479 ITR 770 (Bom)(HC)

S. 260A : Appeal-High Court-Additional evidence-Amalgamation-Non-existing entity-Additional evidence admitted-Assessment was quashed-SLP of revenue dismissed [S. 143(3), 254(1), Code of Civil Procedure, 1908, Order 41, Rule 27, Art. 136]

 

Assessee filed an application under Order 41, Rule 27 of the Code of Civil Procedure, 1908, seeking leave to produce additional evidence in the form of inter-parte documents and communications exchanged between assessee and revenue for the first time before the High Court in appeal proceedings.   High Court held that since the documents sought to be produced as additional evidence would enable Court to pronounce judgment on issue whether the Assessing Officer was aware of amalgamation of RPEL and RPPL with assessee prior to passing of assessment order in the name of non-existent companies, the application was  allowed. Appeal was allowed. SLP of revenue was dismissed.(AY. 1993-94 to 95-96)

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