Statements recorded during survey have no evidentiary value unless corroborated by material evidence

DCIT Vs Vivek Gupta (ITAT Kolkata)

Kolkata Bench of ITAT dismissed Revenue’s appeals & upheld CIT(A)’s deletion of additions u/s 68, disallowance of interest & alleged commission on loans.

AO had treated ₹1.67 crore received from 10 entities as unexplained cash credits, relying on a statement recorded during survey u/s 133A, where Assessee allegedly admitted to taking accommodation entries. Assessee later retracted the statement, claiming it was obtained under duress, & produced full evidences-confirmations, PAN, bank statements, ITRs, & proof of repaym

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