No addition can be made on the basis of mere statement recorded during survey

RELEVANT PARAGRAPH 6. While concluding the statement, the assessee’s surrender is mentioned in the following words:- In the above manner, total surrender in the hands of Gugnani, Trading Co. comes as under :- i) Building A/c Rs.22,90,000. 00 ii) Stock A/c & Cash A/c Rs.15,34,000. 00 Total Rs.38,24,000. 00 The above surrender will be subject to non-initiation of penalty and interest and litigation of prosecution. Further stated that advance tax liability on the additional income, as above, will be paid in accordance with the provisions of Income-tax Act, 1961.” ...