Uncorroborated digital evidence and third-party statements cannot sustain an on-money addition without proper authentication and proof.

An addition for alleged on-money payment under section 69B is said to fail where the Revenue relies mainly on unauthenticated digital material and third-party statements without reliable corroboration. The Tribunal's reasoning, as reflected in the text, is that electronic evidence must have proper authentication and statutory certification, and that seized records or admissions by third parties do not by themselves establish unexplained investment against the assessee when no independent physical evidence, effective corroboration, or tested cross-examination material is produced. The governing principle stated is that suspicion, however strong, cannot replace proof, and the addition was deleted on that basis.

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Issues: Whether the addition under section 69B on account of alleged on-money payment for purchase of immovable property, based on digital material, third-party statements and seized records, was sustainable in the absence of reliable corroboration.

Analysis: The appeals were disposed of by adopting the reasoning already recorded in the connected matter involving the same search action and similar seized material. The material relied on by the Revenue consisted chiefly of a pen-drive extract and statements of third parties. The Tribunal found that the digital material was not sufficiently authenticated, there was no supporting physical evidence from the assessee's premises, and the certificate required for electronic evidence was lacking. The Tribunal also treated the material as lacking independent evidentiary worth against the assessee, particularly when the alleged admissions were from third parties and no effective corroboration or cross-examination support was brought on record. It further followed the settled principle that suspicion, however strong, cannot replace proof.

Conclusion: The addition under section 69B was deleted and the assessee succeeded on the substantive issue.

Ratio Decidendi: An addition for unexplained investment or on-money payment cannot be sustained merely on uncorroborated electronic material and third-party statements lacking proper evidentiary foundation and independent verification.

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