Uncorroborated digital files cannot sustain tax additions for unexplained expenditure or unexplained money without independent verification.

Uncorroborated digital files recovered from a partner's mobile phone could not support additions as unexplained expenditure because their authenticity was not established, the invoice images were not independently verified, and no enquiry was made with customs, shipping agents, suppliers, or the books of account; the additions were deleted. An undated Excel list of alleged sundry debtors also could not sustain an addition as unexplained money because it was not linked to the assessee, bore no date, and was unsupported by independent enquiry or corroborative evidence of unaccounted sales or purchases; that addition was deleted. The decision treats such loose or dumb documents as insufficient by themselves for tax additions.

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Issues: (i) Whether additions as unexplained expenditure based on image files and Excel files recovered from a partner's mobile phone were sustainable for the assessment years under consideration. (ii) Whether addition as unexplained money on the basis of an undated Excel list of alleged sundry debtors was sustainable for the assessment year 2021-22.

Issue (i): Whether additions as unexplained expenditure based on image files and Excel files recovered from a partner's mobile phone were sustainable for the assessment years under consideration.

Analysis: The digital material was not shown to be authentic or reliable. The image files were only said to "appear" to be invoices and the buyer name did not match the assessee's full name and address. No independent enquiry was made with customs authorities, shipping agents, suppliers, or any other source to establish actual import of goods, payment of customs duty, or receipt of shipments. The alleged documents were not corroborated by books of account or any other contemporaneous material. In these circumstances, the seized material was treated as uncorroborated loose papers and not as dependable evidence for making addition.

Conclusion: The additions as unexplained expenditure were not sustainable and were deleted.

Issue (ii): Whether addition as unexplained money on the basis of an undated Excel list of alleged sundry debtors was sustainable for the assessment year 2021-22.

Analysis: The list did not bear the assessee's name, was undated, and was not linked by any independent material to the assessee's business. The provision invoked for unexplained money was held inapplicable to a mere list of alleged debtors. No enquiry was made from the alleged debtors, and no corroborative evidence showed unaccounted sales or purchases generating such balances. The material was therefore treated as a dumb document incapable of supporting the addition.

Conclusion: The addition as unexplained money was not sustainable and was deleted.

Final Conclusion: The impugned additions based solely on uncorroborated digital files could not be sustained, and the assessee obtained full relief on all disputed tax additions.

Ratio Decidendi: Uncorroborated loose papers or digital files, without independent verification or supporting evidence, cannot by themselves sustain additions under the unexplained expenditure or unexplained money provisions.

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