Tribunal held that no addition can be made merely on the basis of the statement given by the assessee. The Assessing Officer had not brought any specific instance of discrepancies in the valuation of closing work-in-progress or any evidence in support of the bogus expenditure incurred by the assessee, but merely based on the statement given by the assessee, had proceeded to make the assessment and the addition. Therefore, the orders of the Assessing Officer as well as the Commissioner (Appeals) were set aside and the Assessing Officer was directed to delete. (AY.2013-14)
Bhagwan Madhukar Kale v. ACIT (2022) 93 ITR 77 (SN) (Pune) (Trib.)
S. 133A : Power of survey-Statement during survey-Addition cannot be made merely on the basis of statement in the course of survey without bringing any corroborative evidence on record-CBDT Instructions F. No. 286/2/2003-It (Inv), Dated 10-3-2003 and F. No. 286/98/2013-It (Inv. Ii), Dated 18-12-2014. [S. 119]