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There is no further evidence regarding the names and addresses of the parties in the said impounded documents and also there is no mention as to who paid such amounts in cash and what is the nature of these transactions as is recorded in loose document marked page 175 and further as to whether these are business transactions or some other transactions. The aforesaid relied upon document marked at page 175 , in our considered view is a dumb document and is not sufficient to fasten tax liability unless the same is corroborated by further incriminating material/evidences on record which in the instant case is lacking. It was also explained by the assessee that tally software containing account books was tempered/manipualted in the night I.T.A. No. 820/Mum/2015 of 19/20-09-2008 to introduced fictitious entries to justify surrender of income to the tune of Rs. 58 lacs. The assessee has also brought report from software / technical experts to substantiate tampering in tally software in the night of 19/20-09-2008 which has remain un-rebutted by Revenue even before us . The Revenue has not chosen to send the said computer system /hard disk for forensic examination by experts to counter aforesaid serious allegations levied by the assessee nor any report of technical expert was called by Revenue to counter allegations of the assessee. These documents were also placed by the assessee before Hon‟ble Bombay High Court in the writ petition filed with Hon‟ble Bombay High Court. The dismissal of the said writ petition no. 2831 of 2008 vide orders dated 06.01.2009 permitting withdrawal of the writ petition by Hon‟ble Bombay High Court is placed in paper book at page no. 106 , wherein Hon‟ble Bombay High court permitted assessee to raise all grievances relating to entries in books of accounts before the authorities during the course of assessment proceedings. CBDT vide letter dated 03-11-2008 has also written letter to the assessee assuring suitable action to resolve grievance of the assessee which is placed on record in paper book. The assessee filed its return of income on 30-09-2009 wherein the said surrendered income of Rs. 1.2 crore was not declared as income in the return of income filed with revenue consequent to the survey u/s. 133A. Thus , in nutshell the assessee made the retraction of the said surrendered income of Rs. 1.20 crore vide letters dated 29.09.2008, 16.10.2008 , filing of writ petition with Hon‟ble Bombay High Court and several other communications with the tax-authorities including CBDT which are placed in record in paper book filed with the Revenue. It is also pertinent to mention that Revenue chose not to cross examine assessee‟s partner Mr Inderjit Singh Khokhar pursuant to retraction of the voluntarily disclosure of Rs. 1.2 crores made by the assessee . The Revenue has also chosen not to place on record report of vigilance and other enquiries initiated by it as directed by CBDT. Now under these circumstances , we have to see whether there is sufficient incriminating material on record to justify additions as were made by the AO . The statement of the partner of the assessee Mr Inderjit Singh Khokar recorded on 19-09-2008 stood retracted by the assessee within 10 days from the date of survey as detailed above . CBDT vide its instruction F.No.286/2/2003-IT(Inv) dated 10-03- 2003 had directed its officers to focus on collection of incriminating material I.T.A. No. 820/Mum/2015 / evidences during the search and survey operations which could lead to detection of undisclosed income rather than focussing on confession of undisclosed income, as under:-