Statement u/s 132(4) is not an incriminating material, Addition unsustainable

ACIT Vs Kuber Khadyan Pvt. Ltd. (ITAT Delhi) Facts- The assessment u/s 153A was completed after making an addition of INR 2,47,00,000/- on account of unexplained credit u/s 68 of the Act. The only dispute is whether there was any incriminating material found during the course of the search. Conclusion- We find that Hon’ble Delhi HC in the case of PCIT Vs. Best Infrastructure Pvt. Ltd. has held that statement under section 132(4) in itself doesn’t constitute incriminating material. Further, Hon’ble Delhi HC in Shri Mulchand Malu has held that statement under section 132(4) alone cannot be...