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2017 (4) TMI 179 - AT - Income TaxAdditions under section 69C - additions solely based on the documents found during the course of survey - Held that:- Merely based on the statement, which was recorded during the course of survey, such additions cannot be made unless such addition is supported by some corroborative evidence. Where the assessee has been able to explain the discrepancy found during the course of survey with regard to purchase price paid for distribution rights, additions cannot be made solely on the basis of statement made by the assessee during the course of survey. In this case, the assessee during the course of survey, in the statement recorded, categorically stated that he has paid ₹1,01,29,747/- , but not ₹ 1,85,00,000/-. The Assessing Officer without any evidence to suggest that the assessee has paid on money in cash over and above the consideration recorded in the books of account, which was further supported by the deposition of producer in the form of letter, wherein he had confirmed receipt of ₹ 1,01,29,747/- additions cannot be made under section 69C of the Act, as unexplained expenditure, towards difference between purchase price found in loose slips and amount recorded in books of account. The Commissioner of Income Tax (Appeals), after considering the relevant facts, has rightly deleted the additions - Decided in favour of assessee
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