Addition cannot be made if no statement is recorded at the time of search

Shivali Bardoliya Brief of the Case: Delhi ITAT held in the case of Smt. Rutu Jindal Vs. ACIT, that if no statement has been recorded at the time of search and where there is no occasion for the assessee to state the fact at the time of search, the addition can not be made without taking in to account the fact of the case which is stated during the appellate proceedings. Brief Facts of the case: Search u/s 132 was conducted at the residence of assessee and a panchnama was prepared for the jewellery owned by different family members of the assessee. During the assessment proceedings the asses...