Delhi tribunal deletes Section 153A additions made on uncorroborated statements

The Income Tax Appellate Tribunal Delhi deleted income tax additions made under Section 153A, ruling that assessments cannot rely strictly on uncorroborated statements gathered during search operations. The bench emphasized that search assessments require tangible, independent evidence rather than verbal admissions alone. Section 153A of the Income Tax Act empowers authorities to assess or reassess income for six preceding assessment years following a search action.

In practice, additions are sometimes made based on statements recorded under oath during searches without backing from seized documents or corroborative records. CAs and tax practitioners handling search and seizure cases must examine assessment orders for additions lacking independent documentary proof and challenge them before appellate authorities.

Professionals should prepare clients to contest uncorroborated statements during scrutiny. Bottom line: Concrete corroborating evidence remains mandatory for sustaining additions under search assessments.