Retracted disclosure under section 132(4) cannot sustain an addition without independent corroborative evidence.

A retracted disclosure recorded under section 132(4) cannot, by itself, sustain an income-tax addition unless supported by independent corroborative evidence. The Tribunal and first appellate authority found that the statement was retracted shortly after it was made, no independent material was brought by the department, and the surrounding facts and account entries had been explained. On those facts, the addition was not disturbed and no substantial question of law arose for interference; the appeal therefore failed and the addition remained deleted.

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Issues: Whether an addition could be sustained solely on the basis of a disclosure statement recorded under section 132(4) of the Income-tax Act, 1961 after the statement had been retracted, and whether any substantial question of law arose for interference.

Analysis: The Tribunal and the first appellate authority found that the disclosure had been retracted within a short time and that the department had not brought on record any independent corroborative material to support the addition. The recorded finding was that a retracted admission, without supporting evidence, was insufficient to justify the addition, particularly when the surrounding facts and account entries had been explained.

Conclusion: The addition was not to be disturbed on the basis of the retracted disclosure alone, and no substantial question of law arose.

Final Conclusion: The appeal failed and the assessment addition remained deleted.

Ratio Decidendi: A retracted disclosure under section 132(4) cannot, by itself, sustain an addition unless it is supported by independent corroborative evidence.

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