No Independent Evidentiary Value For Statement Recorded u/s 133A During Survey: ITAT Deletes ₹9.6

The ITAT has deleted a ₹96 crore "bogus purchases" addition, ruling that a statement recorded under Section 133A during a survey has "no independent evidentiary value." Section 133A allows tax authorities to conduct surveys. This significant decision clarifies that statements recorded during surveys are primarily for gathering information and cannot be the sole basis for making substantial additions to income without corroborating evidence. The ITAT emphasized that such statements must be supported by other independent evidence to be admissible and form the basis of an assessment, providing relief against arbitrary additions.