2018 (7) TMI 468

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....the Respondent JUDGMENT In the present Appeal filed by the Assessee against the Order of the learned Income Tax Appellate Tribunal, Annexure-A dated 27.07.2016, the following purported substantial question of law has been suggested by the Assessee. Whether, on the facts and in the circumstances of the appellant's case, the Appellate Tribunal is right in holding the seized material corroborates....

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....ell as learned Departmental Representative and considered the relevant material on record. The first objection by the learned Authorised Representative is that the original assessment was completed under Section 143(3) and that the original assessment was completed under Section 143(3) and in the reassessment under Section 153A, no addition can be made except based on seized material. We find that....

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....a income which has been clearly corroborated by the seized material. Thus when there is a sufficient evidence seized material which corroborates the statement of the assessee recorded under Section 132(4) on 23.2.2009 then the subsequent retraction of the statement by the assessee without any corroborating evidence cannot be accepted as the assessee has not explained the statement and how the inco....