Unexplained money addition fails where WhatsApp chats lack corroboration and no cash or foreign currency is found.

An addition for unexplained money under section 69A cannot be sustained solely on WhatsApp chat printouts unless the electronic material is supported by independent corroboration and the alleged cash, foreign currency, or other asset is actually found or otherwise established. Where the amount is inferred from chat messages without any physical recovery or reliable supporting evidence, the chats alone do not prove an unexplained money transaction attributable to the assessee. The deeming provision therefore cannot be applied on conjecture, and the addition is deleted.

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Issues: Whether the addition made under section 69A on the basis of WhatsApp chat printouts, in the absence of any corroborative material or physical recovery of cash or foreign currency, was sustainable.

Analysis: The addition rested on WhatsApp messages retrieved during search from the assessee's mobile phone. The Court noted that the amount was worked out by combining an inferred dollar component with a cash figure mentioned in the chat, but no cash, foreign currency, or other incriminating asset was actually found in search. On the facts, the material did not establish that the chat alone proved an unexplained money transaction attributable to the assessee. In the absence of supporting evidence, the seized chats were insufficient to sustain the addition under the deeming provision invoked by the Assessing Officer.

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

Ratio Decidendi: An addition for unexplained money cannot be sustained merely on the basis of electronic chat printouts unless the material is corroborated by independent evidence and the existence of the alleged money or asset is established in search or assessment proceedings.

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