Allowing the appeal of the assessee the Court held that in the statement u/s 132(4) there was no admission on part of assessee that capitation fee. Undisclosed income was offered in the return after the search hence further addition on account of capitalization is held to be not valid.
R. Bhoopathy v. CIT (2019) 263 Taxman 411/ 176 DTR 239 (Mad.)(HC)
S. 68 : Cash credits–Capitalisation fee–Statement on oath-Search and seizure – Undisclosed income was disclosed–Addition of capitalization fee is held to be not valid. [S. 132(4), 158BC]