Search admissions under section 132(4) sustained where seized material corroborated them and retraction lacked supporting evidence.

A sworn admission made during search under section 132(4) that receipts were suppressed and expenses inflated remained reliable where seized blank vouchers and other documents corroborated the statement. A later affidavit retracting only the estimated quantum was treated as self-serving and insufficient because it did not displace the earlier admission with cogent evidence. On that basis, ad hoc restriction of the addition was found unsustainable, and the Assessing Officer's estimate of undisclosed income was restored in full in favour of the Revenue.

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Issues: Whether the addition of undisclosed income based on the partner's statement recorded during search under section 132(4) could be sustained despite a later retraction, and whether the CIT(A) was justified in restricting the addition on an ad hoc basis.

Analysis: The assessee's partner had, in a sworn statement during search, admitted suppression of receipts and inflation of expenses and had estimated undisclosed income at Rs. 5 lakhs. The seized material, including blank vouchers and documentary evidence of unrecorded receipts, corroborated the admission. The subsequent affidavit retracting only the estimate, without cogent evidence to displace the earlier statement, was treated as self-serving and insufficient. In the presence of corroborative incriminating material, the admission under section 132(4), read with the evidentiary principles underlying admissions, remained reliable and formed a valid basis for assessment.

Conclusion: The retraction was not accepted, the ad hoc relief granted by the CIT(A) was held unsustainable, and the addition based on the Assessing Officer's estimate was restored in full, in favour of the Revenue.

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