Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
ITAT reversed additions made under s.69A based on seized digital ledger "Hazir Johri." The disputed ledger "Sanmati 1586" contained merged entries of multiple unrelated parties alongside assessee's transactions. Revenue authorities failed to provide concrete evidence linking assessee to all transactions or substantiate the nature of entries where assessee was named. No corroborative documentation like bills, vouchers, or stock registers established cash sales attribution to assessee. Following precedent where similar merged ledgers were deemed insufficient basis for additions, ITAT held that reliance on Hazir Johri software alone cannot sustain additions without supporting evidence. Assessee's explanation was considered plausible, and additions were deleted.
ITAT reversed additions made under s.69A based on seized digital ledger "Hazir Johri." The disputed ledger "Sanmati 1586" contained merged entries of multiple unrelated parties alongside assessee's transactions. Revenue authorities failed to provide concrete evidence linking assessee to all transactions or substantiate the nature of entries where assessee was named. No corroborative documentation like bills, vouchers, or stock registers established cash sales attribution to assessee. Following precedent where similar merged ledgers were deemed insufficient basis for additions, ITAT held that reliance on Hazir Johri software alone cannot sustain additions without supporting evidence. Assessee's explanation was considered plausible, and additions were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
