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The ITAT held that additions to the assessee's income cannot be made solely based on statements recorded during a search/survey operation u/s 131 of the Income Tax Act, in the absence of any other corroborative tangible evidence. The ITAT relied on the Supreme Court's decision in CIT, Salem, which stated that materials collected and statements obtained during a survey u/s 133A are not conclusive evidence and do not automatically bind the assessee. The ITAT further held that the application of the extrapolation technique depends on the facts and circumstances of each case, and in the present case, no adverse inference can be drawn against the assessee since no documents were found during the search. The ITAT also deleted additions made u/ss 69C and 69B, observing that additions cannot be made merely based on a valuation report without any supporting evidence brought on record by the Assessing Officer.
The ITAT held that additions to the assessee's income cannot be made solely based on statements recorded during a search/survey operation u/s 131 of the Income Tax Act, in the absence of any other corroborative tangible evidence. The ITAT relied on the Supreme Court's decision in CIT, Salem, which stated that materials collected and statements obtained during a survey u/s 133A are not conclusive evidence and do not automatically bind the assessee. The ITAT further held that the application of the extrapolation technique depends on the facts and circumstances of each case, and in the present case, no adverse inference can be drawn against the assessee since no documents were found during the search. The ITAT also deleted additions made u/ss 69C and 69B, observing that additions cannot be made merely based on a valuation report without any supporting evidence brought on record by the Assessing Officer.
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