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2018 (6) TMI 160 - AT - Income TaxSuppression of production leading to the suppression of sale as well as determination of gross profit on estimated basis - statement u/s 133A was recorded on 21-01-2015, wherein, the excess production loss was observed - Held that:- The addition was solely made on the basis of the statement furnished by the production manager of the assessee at the time of survey. The lower authorities have not brought any iota of evidence suggesting that the assessee has suppressed the production leading to suppressed sale out the books. Here it is pertinent to note that the CBDT has discouraged to its officers to make the addition on the basis of the statements and without bringing any tangible materials for any addition/disallowance. Keeping in view the guidelines issued by the CBDT from time to time regarding the statements obtained during search and survey operation, it is undisputedly clear that the lower authorities have not collected any other evidence to prove the suppressed production other than the statement. - Decided against revenue
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