Tribunal held that merely on the basis of statement in the course of survey addition cannot be made, when the said statement was retracted. The assessee has produced documents of all investors hence the addition is deleted. As regards the reopening of assessment is affirmed. Relied on Circular No. 286/2/2003-IT (Inv.), dt. 10th March, 2003. (AY.2012-13)
ACIT v. Jagannathdas Harichandmal Jewellers (P) Ltd (2023) 37 NYPTTJ 1512 /(2024) 167 taxmann.com 17 / 228 TTJ 68 (Raipur)(Trib)
S. 68 : Cash credits-Share application money-Survey-Statement on oath-Retraction-Produced documents of all investors-Merely on the basis of statement addition is not valid-Reassessment-After the expiry of four years-Reassessment on the basis of statement in the course of survey is valid.[S.133A, 147, 148]
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