Third-party electronic records need corroboration before additions can stand; untested statements and no cross-examination made them unsustainable.

Additions under section 69/69A could not be sustained where they were based only on seized third-party Excel sheets and a related statement, without independent corroboration linking the assessee to the entries. A mere name reference and mobile number were insufficient when the sheets covered multiple persons, were not properly decoded or quantified, and no bank trail, cash movement, confirmations, or direct transaction evidence was produced. The assessee had also sought cross-examination of the persons whose statements were relied upon, but no effective opportunity was given. On these facts, the electronic records were treated as uncorroborated material and the additions were held unsustainable and directed to be deleted.

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Issues: Whether additions made under section 69/69A could be sustained solely on the basis of seized third-party excel sheets and statements, without independent corroboration and effective opportunity of cross-examination.

Analysis: The assessment rested on electronic ledgers seized from a third party and on the statement of the person from whom the data was found. The alleged link with the assessee was sought to be drawn from a name reference and a mobile number, but no independent material established a direct nexus between the assessee and the entries. The seized sheets also contained entries relating to multiple persons and were not properly decoded or quantified before the additions were made. No corroborative evidence such as bank trail, cash movement, confirmations, or direct transaction evidence was brought on record. The assessee had specifically sought cross-examination of the persons whose statements were relied upon, but no effective opportunity was afforded. In these circumstances, the electronic records were treated as uncorroborated material incapable of sustaining the additions by themselves.

Conclusion: The additions under section 69/69A were held unsustainable and were directed to be deleted.

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