Search assessment on-money additions must be confined to seized specific entries, not extrapolated to all plot sales without corroboration.

In a search assessment, alleged on-money from plot sales could not be extrapolated across all sales merely on the basis of a seized diary and a statement. The seized entries showed only specific transactions with higher consideration, and there was no corroborative material proving a regular, systematic practice for every plot sale. A retracted statement by itself was insufficient to support a blanket addition. The addition was therefore confined to the specific seized transactions actually recorded, and the proposed uniform rate for all plot sales was rejected.

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Issues: Whether, in a search assessment, the alleged on-money from sale of plots could be extrapolated to all sales on the basis of a seized diary and a statement, or whether the addition had to be confined only to the specific transactions reflected in the seized material.

Analysis: The seized diary contained details of certain plot sales and specific entries of higher consideration, but it did not show that every plot sale involved on-money. A statement recorded during search is relevant evidence, yet its evidentiary value is not absolute and it cannot, by itself, justify a blanket addition unless supported by corroborative material. The retracted statement and the absence of material showing a regular and systematic practice of receiving on-money for all plots meant that year-wise estimation and uniform extrapolation were not justified. The addition could be made only to the extent of the specific transactions actually found recorded in the seized notebook.

Conclusion: The uniform rate of Rs. 100 per sq. yard could not be applied to all plot sales, and the addition was to be restricted to the specific seized entries; the broader extrapolation was rejected.

Ratio Decidendi: In a search assessment, undisclosed income can be brought to tax only to the extent it is supported by seized incriminating material, and a statement alone cannot justify extrapolation to unrecorded transactions without corroboration.

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