Unexplained money additions need corroboration; third-party mobile images and loose notings alone were insufficient here.

Addition for unexplained money based solely on third-party mobile images and loose notings was found unsustainable because there was no independent proof of authorship, possession, cash withdrawal, agreement, or actual payment by the assessee. The alleged recipients denied receiving cash, and those denials were not rebutted by contrary evidence. The electronic material was also unsupported by the certificate required for admissibility of electronic records. On this record, the material was treated as insufficient and uncorroborated, and the deletion of the addition was upheld.

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Issues: Whether the addition of Rs. 2,00,00,000 as unexplained money under section 69A of the Income-tax Act, 1961, based only on third-party electronic images and loose notings, was sustainable.

Analysis: The addition rested on material retrieved from the mobile device of a third party, not from the assessee, and there was no independent proof of authorship, possession, cash withdrawal, agreement, or actual payment by the assessee. The alleged recipients denied receiving any cash, and their denials were not rebutted by contrary evidence. The electronic material was also unsupported by the certificate required under section 65B of the Indian Evidence Act, 1872. In these circumstances, the material was treated as insufficient and uncorroborated for sustaining the addition.

Conclusion: The deletion of the addition was upheld and the Revenue's challenge failed.

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