Reliance Industries Ltd. v. P.L. Roongta, CIT (2025) 343 CTR 401 / 246 DTR 353 / 171 taxmann.com 467 (Bom)(HC) CIT v. Reliance Polypropylene Ltd. (2025) 343 CTR 401 / 246 DTR 353 / 171 taxmann.com 467 (Bom)(HC)

S. 260A : Appeal-Additional evidence-Communications exchanged between assessee and Revenue-Admissible as evidence in appeal proceedings. [CPC, 1908, O. XLI, r. 27; Art. 226]

The assessee sought to produce additional evidence in the form of letters and computation notes showing that the AO had knowledge of amalgamation before passing the order. These were inter-parte documents already on record of the Revenue. The Court held that under O. XLI r. 27(b), CPC, such documents can be admitted to enable the Court to pronounce judgment. Accordingly, objections of the Revenue were rejected and the additional evidence was admitted. (AY. 1992-93 to 1995-96)

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