Acit 32(2), Mumbai vs Mangalsingh M Rathod, Mumbai on 14 June, 2017
He has also relied upon the order of the ITAT
Ahmedabad Bench in the case of ACIT Vs Jorawar Singh M. Rathod
94 TTJ 867 in which it was held that "addition made by the AO
merely on the basis of retracted statement under s. 132(4) could
not be sustained in the absence of any evidence, material or
recovery of any movable or immovable assets at the time of
search to corroborate the disclosure made by the assessee." He
has similarly, relied upon the decision reported in 128 ITD 75 (TM)
Agra.