2025 (12) TMI 332

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.... ORDER Per Bench This is an appeal filed by the revenue against the order of the Id CIT(A)-Patna-3, dated 21.6.2021 in Appeal No. CIT(A) Patna-3/10628/2016-17, for the assessment year 2014-15. 2. Shri Devesh Poddar, Id AR appeared for the assessee. Shri Rajat Datta, Id CIT DR represented on behalf of the revenue. 3. Ld CIT DR submitted that there was a search in the Bhalotia group of....

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....at the ld CIT(A) held that the addition cannot be made on the basis of a statement of submission of the director of the assessee company until and unless there is any corroborative evidence for the same. It was the submission that the assessee having offered the said income in the course of search, the M Y addition is liable to be upheld. It was the prayer that the order of the ld CIT(A) is liable....

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.... the director of the assessee company in the form of statement. A perusal of the said statement shows that the assessee has clearly mentioned thereon that " we beg to offer an addition al income of Rs. 6,00,00,000/- for A.Y. 2014-15, which is offered for taxation by the assessee. In this respect, we beg to submit that there are certain debtors from whom we have to realize substantial amount. We ar....

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....eing brought to tax on the basis of any seized documents or any evidence to suggest such income. The addition has been made only on the basis of the statement made by the assessee. The facts in the present case clearly shows that for the purpose of bringing any group income to tax, one of the primary requirement is the filing of revised return. Just because, the assessee makes a statement, the inc....