Without Incriminating Material Section 133A Survey Statements Lack Evidentiary Value

DCIT Vs Pragati Agri Products Pvt. Ltd. (ITAT Kolkata) Income Tax Appellate Tribunal (ITAT) Kolkata upheld the order of the Commissioner of Income Tax (Appeals) [CIT(A)] in the case of DCIT Vs Pragati Agri Products Pvt. Ltd. for the Assessment Year 2016–17, emphasizing that statements recorded during a survey under Section 133A of the Income Tax Act lack evidentiary value unless supported by incriminating material. This case arose when the Assessing Officer (AO) made an addition of ₹2.39 crores to the assessee’s income based on discrepancies noted during a survey, such as differing g...