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Additions cannot be sustained merely on the basis of statement given during the course of search without correlating the addition with the incriminating seized material.

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Section 132 of the Income Tax Act, 1961—Search and Seizure—Statement of partner containing surrender for various group concerns and not specifically for assessee cannot be treated as statement under section 132(4) in case of assessee, thus, addition by the AO not on basis of incriminating material found during course of Search but only on basis of statement of partner of assessee were deleted— Ultinate Builders vs. Assistant Commissioner of Income tax [2019] 74 ITR (trib) 566 (Indore)

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