The AO made addition on account of unaccounted investment and unaccounted purchases on the basis of statement made before Custom Authorities . On appeal the CIT (A) held that  the AO did not make further inquiries and that the only evidence with the AO was in the form of confessional statement of the partner of the assessee recorded on oath under section 108 of the Customs Act, 1962 and that in the absence of any corroborative evidence or finding, no addition could be made merely on the basis of the admission statement. The Tribunal found that the addition was made based on the show-cause notice issued by the Revenue Intelligence, that the statement was retracted by the partner and that the Customs Excise and Service Tax Appellate Tribunal had dropped the proceeding initiated against the assessee. The Tribunal held that in the absence of any documentary evidence no addition could be made on the action of a third party, i. e., the Directorate of Revenue Intelligence. On appeal  by the revenue  dismissing the appeal the Court held that the Tribunal was correct in holding that no addition could be made on the basis of the action of the third party, i. e., the Directorate of Revenue Intelligence. The Department could not start with the confessional statement of the assessee. The confessional statement had to be corroborated with other material on record. The appellate authorities had concurrently recorded a finding that except the statement of the partner recorded under section 108 of the 1962 Act there was no other evidence.   Relied on Bannalal Jat Constructions (P.) Ltd. v. Asst. CIT [2019] 106 taxmann.com 128 (SC)  ( AY. 2007-08)