Survey statement alone cannot sustain undisclosed income addition without corroborative evidence or specific incriminating material.

Undisclosed income added solely on the basis of a survey statement could not be sustained where the statement was retracted and the record lacked specific incriminating material or corroborative evidence. The tribunal noted that there were no particulars of the alleged land transactions, no identification of buyers or sellers, and no material explaining how the alleged income figure was computed. Applying the principle that a confession or admission during survey does not by itself justify an addition, the tribunal held that assessment must rest on evidence, not on statement alone, and deleted the addition.

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Issues: Whether the addition of undisclosed income sustained solely on the basis of the assessee's survey statement, later retracted, was justified in the absence of specific incriminating material or corroborative evidence.

Analysis: The addition was founded primarily on a statement recorded during survey proceedings. The record did not contain specific details of land transactions, identification of buyers or sellers, the properties allegedly dealt with, or any material showing how the figure of Rs. 14 crores was arrived at. The retraction was considered against the backdrop of the absence of supporting evidence. The legal position applied was that a confession or admission recorded during survey does not, by itself, justify an addition unless supported by corroborative material. The cited judicial authorities and CBDT instruction emphasized that assessment should rest on evidence gathered, not on confession alone.

Conclusion: The addition was not sustainable and was deleted.

Ratio Decidendi: An addition for undisclosed income cannot be sustained merely on a survey statement when the statement is retracted and no corroborative evidence links the assessee to the alleged income.

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