Additions made of amount surrendered after adjusting expenditure was justified

Brief about the case

In the case of Raj Hans Towers Pvt. Ltd. Vs.  CIT, Delhi High Court held that discretion vested in the Revenue authorities in content and character is not radically different in the case of a survey or in the case of search and seizure operations as is evident from a plain reading of Section 133A (3) and 132(4) and so the AO may use his discretion to use the recorded statement as a relevant material. HC held that where assessee had not offered any satisfactory explanation regarding surrendered amount not being bona fide and it was also not borne out in any contentions raised before lower authorities, additions so made after adjusting expenditure were justified.

Facts of the case:

• The assessee company was engaged in real estate and contruction activities which was subjected to survey u/s 133A.

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