Addition based on survey proceeding - Unexplained stock of gold and silver jewellery - The statement...

Addition based on survey proceeding - Unexplained stock of gold and silver jewellery - The statement given during the course of survey is not a statement on oath as given u/s. 132(4) of the Act and therefore has no evidentiary value. Reliance should be placed upon the evidence/materials gathered during the course of survey operations while framing the assessment orders. Therefore this finding of Ld. CIT(A) that the assessee was required to honour income surrendered during the course of survey and offer it to tax finds no merit. - AT .....

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