Survey statement alone cannot sustain addition when books match and no corroborative evidence of undisclosed income is found.

An addition based solely on a survey statement was held unsustainable where the assessee's books and declared profit results broadly matched the estimated figure and no discrepancy or unaccounted income was found. The estimate given during survey was treated as an approximate projection, not as an admission of undisclosed income. In the absence of independent corroborative material, the statement alone could not justify the addition. The assessee's later explanation regarding partner remuneration was also consistent with the survey estimate and remained unrebutted. The addition was therefore deleted, with the matter decided in favour of the assessee and against the Revenue.

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Issues: Whether the addition of Rs. 50 lakhs, made on the basis of a statement recorded during survey, was sustainable when the assessee's books of account and profit results broadly matched the estimate given and no discrepancy or unaccounted income was found.

Analysis: The estimated figure stated during survey was treated as an approximate projection of income and not as an admission of unexplained or additional income. The profit and loss account showed results broadly in line with the estimate, and no material discrepancy was noticed in the books during survey or assessment. The addition was made only on the basis of the survey statement without independent corroborative evidence. The record also showed that the assessee's subsequent explanation regarding partner remuneration was consistent with the estimate given during survey and was not rebutted by contrary material.

Conclusion: The addition of Rs. 50 lakhs was not justified and was rightly deleted; the appeal was decided against the Revenue and in favour of the assessee.

Final Conclusion: A survey statement showing an approximate income estimate, without supporting evidence of undisclosed income or book discrepancies, cannot by itself sustain an addition.

Ratio Decidendi: An addition based solely on a survey statement is unsustainable where the books of account and declared results are broadly consistent with the estimate and no corroborative evidence of undisclosed income is found.

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