Survey admissions backed by documents sustained addition where no timely retraction or proof of coercion was shown.

Survey material showing receipts in the assessee's concern name, together with the assessee's recorded admission, supported an addition for undisclosed income. The assessee's plea of coercion failed because no contemporaneous retraction was made and no credible evidence was produced to displace the survey documents. Reliance on the CBDT circular did not assist the assessee where the disclosure was backed by tangible material found during survey. The addition was therefore sustained.

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Issues: Whether the addition of Rs. 19,41,740 made on the basis of documents found during survey and the assessee's statement recorded in the survey could be sustained despite the plea of coercion and absence of retraction.

Analysis: Documents found in the course of survey showed receipts aggregating to Rs. 19,41,740 in the name of the assessee's concern. The assessee's statement admitting the amount as undisclosed income was recorded on the basis of those materials. No contemporaneous retraction was made before the authorities, and no plausible evidence was produced to show coercion or to dislodge the survey material. The reliance placed on the CBDT circular did not help the assessee because the disclosure was supported by tangible evidence found during survey.

Conclusion: The addition was correctly sustained and the assessee's challenge failed.

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