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Addl Cit Large Tax Payer Unit, Mumbai vs Reliance Industries Ltd, Mumbai on 12 April, 2017

22.2. The learned Authorized Representative continued his submissions with a meticulous reference to jurisprudence, weaving together a formidable chain of precedents that underscored the impermissibility of making additions solely on the strength of uncorroborated and subsequently retracted statements. He first drew our attention to the decision of the Hon'ble Bombay High Court in CIT v. Reliance Industries Ltd. [(2020) 261 Taxman 358 (Bom)], where the Court had categorically held that a statement recorded during search cannot be relied upon as conclusive evidence unless supported by independent material. In that case, as in the present one, the Assessing Officer had based additions merely on the confession of a third party without any corroboration, which was later retracted. The High Court, affirming the Appellate Tribunal, ruled that when a statement is retracted and no other evidence is adduced, such a statement cannot, by itself, justify the addition. The learned counsel submitted that the ratio of this judgment was directly applicable to the present facts, where the Assessing Officer, resting solely on the statements of TNS, had proceeded to frame the assessment without any verification or corroboration from the alleged payers or any independent third-party evidence.
Income Tax Appellate Tribunal - Mumbai Cites 91 - Cited by 73 - Full Document

Shree Swami Samarth Trading Co. P. Ltd, ... vs Cit (A)-13, Mumbai on 31 May, 2017

23. The learned AR next placed reliance on the judgment of the Hon'ble Jharkhand High Court in Shree Ganesh Trading Co. v. CIT [(2012) 214 Taxman 262 (Jharkhand)], wherein it was held that though a statement recorded under section 132(4) constitutes evidence, its reliability and probative worth depend on the surrounding circumstances and corroboration. The Court observed that a bald statement, made without contemporaneous recovery of cash 14 ITA Nos. 3233, 3232 & 3229/Mum/2025 Govind Corporation AYs 2012-13 to 2014-15 or assets and later retracted, could not be used to fasten liability. Drawing a parallel, the learned counsel emphasised that in the assessee's case, no incriminating cash or valuables had been discovered in the course of search; yet, the Assessing Officer had proceeded as though the excel sheet were self-proving instruments of truth. Such an approach, he argued, stood condemned by judicial authority.
Income Tax Appellate Tribunal - Mumbai Cites 15 - Cited by 9 - Full Document

Central Bureau Of Investigation vs V.C. Shukla & Ors on 2 March, 1998

In support of this proposition, the learned AR drew strength from the celebrated decision of the Hon'ble Supreme Court in Central Bureau of Investigation v. V.C. Shukla & Ors. [Criminal Appeal Nos. 247-256 of 1998], wherein it was held that loose sheets or diaries, not being books of account regularly kept in the course of business, are not admissible evidence under section 34 of the Indian Evidence Act. The Court observed that entries made by one person in such documents, unless corroborated by independent evidence, cannot fasten liability on another. This, the AR submitted, was directly applicable to the present case, where the Assessing Officer sought to tax the assessee on the strength of the personal notings of PDG, without establishing authorship, authenticity, or relevance.
Supreme Court of India Cites 35 - Cited by 551 - M K Mukherjee - Full Document
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