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The ITAT set aside the impugned additions under s.153C, holding that the seized digital ledger maintained in the 'Hazir Johri' software did not constitute admissible evidence tying the appellant to the alleged receipts. The Tribunal found the ledger contained less than fifty percent of transactions relatable to the appellant, relied on unexplained pseudonyms, and rested on witness statements that were neither furnished to nor cross-examined by the appellant. In light of these procedural infirmities and lack of nexus between the seized material and the appellant, the additions founded on the seized software entries were deleted and the appeal allowed.
The ITAT set aside the impugned additions under s.153C, holding that the seized digital ledger maintained in the 'Hazir Johri' software did not constitute admissible evidence tying the appellant to the alleged receipts. The Tribunal found the ledger contained less than fifty percent of transactions relatable to the appellant, relied on unexplained pseudonyms, and rested on witness statements that were neither furnished to nor cross-examined by the appellant. In light of these procedural infirmities and lack of nexus between the seized material and the appellant, the additions founded on the seized software entries were deleted and the appeal allowed.
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