https://www.taxtmi.com/caselaws?id=221524 In a challenge to deletion of penalty under s.271(1)(c) and allied additions, the HC held that a statement recorded during survey under s.133A, though a relevant admission, is not conclusive and has evidentiary value only when corroborated by independent material. As the Department failed to verify alleged gold with third-party artisans and could substantiate the admission only to the extent of actual seizure, the addition for the balance gold was rightly set aside; consequential penalty could not survive. For cash found, the ITAT correctly remitted the matter to the AO to verify linkage with prior bank withdrawal; deletion otherwise was not erroneous. Enhancements for money-lending investment/interest and other heads, based on rough estimates and an unsworn s.133A statement alone, were rightly deleted; the tax appeal was dismissed. en-us Wed, 06 Mar 2013 00:00:00 +0530 Thu, 18 Dec 2025 13:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=221524 In a challenge to deletion of penalty under s.271(1)(c) and allied additions, the HC held that a statement recorded during survey under s.133A, though a relevant admission, is not conclusive and has evidentiary value only when corroborated by independent material. As the Department failed to verify alleged gold with third-party artisans and could substantiate the admission only to the extent of actual seizure, the addition for the balance gold was rightly set aside; consequential penalty could not survive. For cash found, the ITAT correctly remitted the matter to the AO to verify linkage with prior bank withdrawal; deletion otherwise was not erroneous. Enhancements for money-lending investment/interest and other heads, based on rough estimates and an unsworn s.133A statement alone, were rightly deleted; the tax appeal was dismissed. Case-Laws Income Tax Wed, 06 Mar 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=221524