Uncorroborated WhatsApp chats cannot justify unexplained investment additions without independent evidence or verified fund movement.

An addition based solely on an uncorroborated WhatsApp chat or loose digital note cannot be sustained where the figure relied on is arbitrarily inflated without independent evidence. The Tribunal treated the third-party digital material as a dumb document because it was not seized from the assessee and was unsupported by bank records, ledgers, statements, or proof of actual fund movement. It also noted that the presumptions under sections 132(4A) and 292C do not apply where the material is not found in the assessee's possession and remains unverified. For a non-resident assessee, an unproved digital entry could not establish unexplained investment or taxable income in India, and the addition was deleted.

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Issues: Whether an addition under section 69 could be sustained solely on the basis of an uncorroborated WhatsApp chat/loose digital note indicating a figure of 550, and whether such material could establish unexplained investment in the hands of a non-resident assessee.

Analysis: The addition was founded on a WhatsApp chat recovered from a third party's device, with the figure 550 being treated by the Assessing Officer and DRP as Rs. 5.50 crore by adding five zeros without any independent basis. The material was not seized from the assessee and was not supported by any corroborative evidence such as bank entries, ledger records, statements of the parties, or any other material proving actual movement of funds. The Tribunal held that loose or unsigned digital material without supporting evidence is a dumb document and cannot, by itself, justify an adverse inference. It further noted that the deeming presumptions under sections 132(4A) and 292C do not assist where the material is not found from the assessee's possession and the contents remain unverified. The assessee being a non-resident, no income was shown to have accrued or arisen in India, and an arbitrary figure in an uncorroborated chat could not be treated as real taxable income.

Conclusion: The addition under section 69 was deleted and the issue was decided in favour of the assessee.

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