Dismissing the appeal of the revenue the Court held that , the Department could not dispute that the statement recorded during search and seizure could have been explained subsequently and also that after examining the entire material on record, the actual concealment apparent from record was much less than that disclosed by the assessee. Further, the assessee was entitled to explain his statement made during search and seizure operation. Therefore, the Tribunal was right in holding that there was no concealment on the part of the assessee.[BP.1-4-1996 to 13-9-2002 ]
CIT v. S. K. D. New Standard Coaching Institute (2018) 407 ITR 529 (All) (HC)
S. 158BC : Block assessment -Undisclosed income — Amount surrendered in the course of survey- Merely on the basis of statement in the course of search or survey addition cannot be made, if the assesseee is able to explain the differences- Actual concealment was less than the amount surrendered -Deletion on the basis of explanation is held to be valid . [ S. 132,133A ]