Dismissing the appeal of the revenue the Court held that, merely on the basis of statement recorded in the course of search, which was retracted, with in a short time by filing an affidavit. Subsequently his further statement was recorded he reiterated the stand taken in affidavit. Court held that no disallowance of consultancy charges can be made without bringing on record independent material.
CIT v. Reliance Industries Ltd. (2019) 261 Taxman 358 /(2020) 421 ITR 686 (Bom.)(HC) Editorial : SLP is granted to the revenue, CIT v. Reliance Industries Ltd. (2019) 418 ITR 13 (St) (SC) /( 2020) 270 Taxman 19 (SC)
S. 37(1) : Business expenditure –Consultancy charges –Statement – Retraction- Merely on the basis of statement recorded in the course of search, which was retracted–No disallowance can be made without bringing on record independent material. [S. 132(4)]