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    <title>Additions under s.153A and disallowances based solely on retracted s.132(4) statement struck down without corroboration</title>
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    <description>The ITAT allowed the assessee&#039;s challenges to additions made under s.153A and disallowances premised solely on a statement allegedly recorded u/s 132(4) where no incriminating material was seized and the statement was retracted, holding such statement lacked evidentiary value and cannot sustain additions absent corroboration; accordingly ground nos. addressing that issue were allowed. The Tribunal held the AO&#039;s sample one-month extrapolation and permutation-and-combination estimates were arbitrary and impermissible. The Tribunal nonetheless upheld a limited disallowance for amounts characterised as penal (&quot;Shashti&quot;) while treating other payments as compensatory, and disallowed the CIT(A)&#039;s direction compelling fresh month-wise submissions as beyond authority; relevant grounds were partly allowed/allowed.</description>
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    <pubDate>Sat, 27 Sep 2025 08:34:37 +0530</pubDate>
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      <title>Additions under s.153A and disallowances based solely on retracted s.132(4) statement struck down without corroboration</title>
      <link>https://www.taxtmi.com/highlights?id=92903</link>
      <description>The ITAT allowed the assessee&#039;s challenges to additions made under s.153A and disallowances premised solely on a statement allegedly recorded u/s 132(4) where no incriminating material was seized and the statement was retracted, holding such statement lacked evidentiary value and cannot sustain additions absent corroboration; accordingly ground nos. addressing that issue were allowed. The Tribunal held the AO&#039;s sample one-month extrapolation and permutation-and-combination estimates were arbitrary and impermissible. The Tribunal nonetheless upheld a limited disallowance for amounts characterised as penal (&quot;Shashti&quot;) while treating other payments as compensatory, and disallowed the CIT(A)&#039;s direction compelling fresh month-wise submissions as beyond authority; relevant grounds were partly allowed/allowed.</description>
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      <pubDate>Sat, 27 Sep 2025 08:34:37 +0530</pubDate>
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