Additional evidence

The affidavit filed before the CIT(A) without any formal application, and which was not even allowed, cannot form part of the additional evidence, and that too, without giving opportunity to the revenue to rebut the said evidence, as held by KolHC in Dinesh B Parikh v CIT — In favour of: The assessee; ITA No 324 of 2003.

Block assessment — When sufficient evidence has not been produced by the assessee to rebut the statement made at the time of the search, which was regarding the investment under different names but where the shares actually belonged to him, additions made in the block assessment are not liable to be interfered with.

Decided on: 2 August 2011.