https://www.taxtmi.com/caselaws?id=771315 The ITAT Delhi ruled against the revenue department in a search and seizure case where additions were made based solely on a statement recorded under section 132(4). The appellant had initially admitted undisclosed income of Rs. 10 crores during search proceedings but later retracted the statement. The tribunal found no incriminating material was seized during the search operation that supported the alleged undisclosed income. The assessee provided explanations for all seized documents, none of which pertained to undisclosed transactions. The tribunal held that mere statements under section 132(4) without supporting incriminating material are insufficient for additions, particularly under the new legal framework requiring mandatory incriminating material for assessments beyond three years post-search. The addition was deleted. en-us Wed, 21 May 2025 00:00:00 +0530 Fri, 23 May 2025 08:46:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771315 The ITAT Delhi ruled against the revenue department in a search and seizure case where additions were made based solely on a statement recorded under section 132(4). The appellant had initially admitted undisclosed income of Rs. 10 crores during search proceedings but later retracted the statement. The tribunal found no incriminating material was seized during the search operation that supported the alleged undisclosed income. The assessee provided explanations for all seized documents, none of which pertained to undisclosed transactions. The tribunal held that mere statements under section 132(4) without supporting incriminating material are insufficient for additions, particularly under the new legal framework requiring mandatory incriminating material for assessments beyond three years post-search. The addition was deleted. Case-Laws Income Tax Wed, 21 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771315