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 upheld the CIT(A)'s deletion of additions u/s 68 and 69A made on the basis of a seized day-cash-book/diary belonging to a third-party group. It held that unilateral decoding of notings by the AO, without examining the author or any connected person and without corroboration from bank records, audited books, confirmations or other primary evidence, lacked evidentiary value. As the loose sheets neither named the assessee nor established a one-to-one nexus with recorded cheque transactions, they were treated as "dumb documents." Additions based on such unverified third-party loose papers were held unsustainable, and the appeals were decided in favour of the assessee.
ITAT upheld the CIT(A)'s deletion of additions u/s 68 and 69A made on the basis of a seized day-cash-book/diary belonging to a third-party group. It held that unilateral decoding of notings by the AO, without examining the author or any connected person and without corroboration from bank records, audited books, confirmations or other primary evidence, lacked evidentiary value. As the loose sheets neither named the assessee nor established a one-to-one nexus with recorded cheque transactions, they were treated as "dumb documents." Additions based on such unverified third-party loose papers were held unsustainable, and the appeals were decided in favour of the assessee.
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