Dismissing the appeal of the Revenue the Tribunal held  that all  the key employees of the assessee, an educational trust, having retracted from their statements recorded under S. 132(4) by filing affidavits deposing that the search officers recorded the statements contrary to the replies given by them, said statements have no evidentiary value.  in the absence of any independent corroborative evidence, to come to the conclusion that the assessee has been receiving capitation fees from the students of its institutions, addition was not sustainable. Seized torn pieces of paper pasted on another paper in haphazard and disjoint manner bearing some names and figures which cannot be correlated with each other cannot be treated as incriminating material suggesting that the assessee has been accepting capitation fee. In the absence of any incriminating material suggesting undisclosed income, there is no question of extrapolation of addition in the previous year or subsequent year. Order of CIT(A) deleting the addition was affirmed. Application under Rule 27 was  filed challenging the validity of the proceedings under section 153C of the Act was dismissed  as the issue was not raised before the Assessing Officer or CIT(A) and the assessee has filed the letter stating that they will not raise any technical  grounds in the appeal.     (AY. 2005-06 to 2011-12)