Composite GST notices, mandatory limitation, and same-subject bar: HC upheld valid notices but quashed overlapping proceedings and unauthorised withho...
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A search statement under section 132(4) was held insufficient by itself to sustain an addition under section 69A where it was promptly retracted and no corroborative incriminating material was found. The Tribunal noted that the assessee explained the circumstances of the statement, while the Assessing Officer produced no seized jewellery, cash deposits, bank material, documentary trail, or other independent evidence to support the alleged receipt or its application. Because the addition rested only on the retracted statement and the statutory burden was not discharged by independent corroboration, the appellate deletion of the addition was upheld.
A search statement under section 132(4) was held insufficient by itself to sustain an addition under section 69A where it was promptly retracted and no corroborative incriminating material was found. The Tribunal noted that the assessee explained the circumstances of the statement, while the Assessing Officer produced no seized jewellery, cash deposits, bank material, documentary trail, or other independent evidence to support the alleged receipt or its application. Because the addition rested only on the retracted statement and the statutory burden was not discharged by independent corroboration, the appellate deletion of the addition was upheld.
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