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ITAT dismissed the Revenue's appeal and upheld the assessee's stance, setting aside the addition under s.69. The Tribunal found the impugned WhatsApp screenshots unauthenticated, lacking any official signature or section 65B(4) certificate, and noted absence of the source device; thus the digital excerpts were inadmissible and susceptible to fabrication. The AO failed to obtain corroboration from Registration/Stamp Duty authorities, ignored the government-fixed stamp duty rate, and produced no comparable market evidence; the contested market-value computation appeared conjectural. No independent evidence of unexplained cash receipts was established, rendering the addition speculative and unsustainable.
ITAT dismissed the Revenue's appeal and upheld the assessee's stance, setting aside the addition under s.69. The Tribunal found the impugned WhatsApp screenshots unauthenticated, lacking any official signature or section 65B(4) certificate, and noted absence of the source device; thus the digital excerpts were inadmissible and susceptible to fabrication. The AO failed to obtain corroboration from Registration/Stamp Duty authorities, ignored the government-fixed stamp duty rate, and produced no comparable market evidence; the contested market-value computation appeared conjectural. No independent evidence of unexplained cash receipts was established, rendering the addition speculative and unsustainable.
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