Income Tax Act: Statements u/ss 153A and 132(4) require proof and cross-examination to affect third parties.

Assessment u/s 153A - admission made u/s 132(4) - The fundamental difference between evidentiary value of statement under S. 132(4) against the maker of statement vis-a-vis a third party has not been recognised by the revenue. The statement of the maker may possibly operate as estoppel against him in certain circumstances. However, truthfulness thereof is required to be proved beyond doubt for it to bind a third party. The deptt. was duty bound to give cross examination of the maker where it seeks to rely upon it. - AT .....

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