Addition based on mere statement of assessee which is retracted is not sustainable

After reproducing Section 69C and adverting to the fact that Dilip Dherai has retracted his statement,  the Tribunal arrived at the conclusion that merely on  the strength of the alleged admission in the statement of  Dilip Dherai, the additions could not have been made. The concurrent findings of fact would demonstrate that the  essential ingredients of Section 69C of the IT Act enabling the additions were not satisfied. This is not a case of ‘no  explanation’. Rather, the Tribunal concluded that the allegations made by the authorities are not supported by actual cash passing...