Retracted search statements cannot alone sustain additions without corroborative evidence of undisclosed income.

Additions based only on statements recorded during a search were not sustainable where the statements were later retracted as involuntary and no corroborative material was found. The partners stated that the admissions were made under pressure, and the search yielded no incriminating documents, loose papers, or other independent evidence of undisclosed income. In such circumstances, a retracted statement recorded during a prolonged search cannot, by itself, justify additions. The Tribunal therefore deleted the additions.

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Issues: Whether additions could be sustained solely on the basis of statements recorded during search when those statements were later retracted and no corroborative material was found.

Analysis: The assessee's partners retracted their statements recorded during the search and asserted that the admissions were made under pressure. No incriminating documents, loose papers, or other supporting evidence were found during the search to justify the additions. The Tribunal held that a statement recorded in the course of a prolonged search, if shown to be involuntary and retracted on proper grounds, cannot by itself constitute sufficient material for making additions. In the absence of independent evidence supporting the alleged undisclosed income, the additions could not be upheld.

Conclusion: The additions were not sustainable and were deleted.

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