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ITAT held that statements recorded u/s 132(4) cannot be solely used as substantive evidence for income additions without independent corroboration. The tribunal found that loose papers and partner's statement were insufficient to substantiate undisclosed income claims. No material evidence was discovered during search to support the alleged income surrender. The statement alone, without additional substantive proof, cannot form basis for tax assessment. The appellate tribunal consequently deleted the income addition and allowed the assessee's appeal, reinforcing the legal principle that unsubstantiated statements lack evidentiary value in tax proceedings.
ITAT held that statements recorded u/s 132(4) cannot be solely used as substantive evidence for income additions without independent corroboration. The tribunal found that loose papers and partner's statement were insufficient to substantiate undisclosed income claims. No material evidence was discovered during search to support the alleged income surrender. The statement alone, without additional substantive proof, cannot form basis for tax assessment. The appellate tribunal consequently deleted the income addition and allowed the assessee's appeal, reinforcing the legal principle that unsubstantiated statements lack evidentiary value in tax proceedings.
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