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 directed deletion of additions made under s.69A, holding that undocumented loose paper found at a third party's residence could not sustain an unexplained income addition against the assessee. The Tribunal found the AO's reliance on unsubstantiated inference from initials and an audio recording insufficient: the seized paper was undated and thus presumptively related to the year of search (FY 2020-21/AY 2021-22), not the assessment year to which the additions were made; no cash or corroborative documents were seized from the assessee; no enquiries were pursued concerning running bills; and the audio had no nexus to the assessee. Accordingly, additions based on the seized entries were deleted and grounds 1-3 were allowed.
ITAT directed deletion of additions made under s.69A, holding that undocumented loose paper found at a third party's residence could not sustain an unexplained income addition against the assessee. The Tribunal found the AO's reliance on unsubstantiated inference from initials and an audio recording insufficient: the seized paper was undated and thus presumptively related to the year of search (FY 2020-21/AY 2021-22), not the assessment year to which the additions were made; no cash or corroborative documents were seized from the assessee; no enquiries were pursued concerning running bills; and the audio had no nexus to the assessee. Accordingly, additions based on the seized entries were deleted and grounds 1-3 were allowed.
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