No additions could be made merely on basis of statement u/s 132(4) without incriminating evidence

Dr. Purvesh Mansukhlal Shah Vs ITO (ITAT Ahmedabad) Conclusion: Assessee could not have been subjected to additions in case of search/survey operations merely on basis of statement recorded under section 132(4) unless and until some corroborative evidence was found in support of such admission. Held: Assessee was subjected to a survey under Section 133A where he disclosed ₹14 crores as undisclosed income for the assessment year (AY) 2012-13. He admitted to earning this income through unaccounted cash from land dealings as a land broker. However, in the return filed for AY 2012-13, he declare...