On-money addition fails without corroboration and admissible electronic evidence, leading to deletion of the tax addition.

An addition for alleged on-money payment could not be sustained where it rested only on a builder's statement and electronic material, without independent corroboration from the assessee. The Tribunal also found that the electronic evidence was not shown to meet the admissibility requirements under section 65B of the Indian Evidence Act, 1872. In the absence of reliable supporting material, the foundation for the addition was insufficient, and the addition was deleted.

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Issues: Whether the addition on account of alleged on-money payment was sustainable in the absence of corroborative material and in view of the admissibility of the electronic evidence relied upon by the Revenue.

Analysis: The addition was founded only on a statement of the builder and on electronic material said to have been found during search. No independent corroborative material from the assessee was shown to support the alleged cash payment. The Tribunal also noted that the electronic evidence relied upon by the Revenue was not shown to satisfy the requirements of admissibility under section 65B of the Indian Evidence Act, 1872. In these circumstances, the basis for sustaining the addition was found insufficient.

Conclusion: The addition was not sustainable and was directed to be deleted.

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