Addition/Disallowance Can’t Be Made Merely On Assessee’s Admission During Search

Case: PCIT Versus PGF Ltd.

Coram: Justice Manmohan and Justice Manmeet Pritam Singh Arora

Case No.: ITA 528/2019

Court Observation: “The Appellant-Revenue has not placed reliance on or even referred to any statement recorded under Section 132(4) of the Act, 1961. No statement has been produced before this Court. Therefore, in the facts of the present case, the issue does not arise for consideration unless it can be demonstrated by the Appellant-Revenue that the statements recorded under Section 132(4) disclose some incriminating material on the basis of which orders under Section 153A have been passed,”

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Keywords

Addition/Disallowance, Assessee’s Admission