Held that no Will was produced before the AO and CIT(A), however, at the stage of appeal before the Tribunal, the assessee produced the Will which was considered by it. The Tribunal has found that there was no application moved under R. 46A and the additional evidence as well as grounds regarding the Will having been executed in favour of the assessee, could not have been considered. Provisions of the Act of 1961 are to be read as it is. No addition or subtraction can be made in the Rules of 1962 nor any principles of natural justice, where not applicable, can be applied, nor can any other provisions regarding equity be made applicable while construing the provisions of the Rules. It is an admitted position that there was a violation of R. 46A and therefore, such documents could not be taken into consideration. No reason has come forward for not placing the so-called Will during the time of assessment.(AY. 2011-12)