Mere admission of estimated income made during survey has no evidentiary value

Shri Amod Shivlal Shah Vs ACIT (ITAT Mumbai)

Assessments ought not to be based merely on the confession obtained at the time of search and seizure and survey operations, but should be based on the evidences/material gathered during the course of search/survey operations or thereafter, while framing the relevant assessments.

We have carefully considered the rival submissions. Insofar as the factual position is concerned,  there is no dispute that when the s

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