ITAT allowed the assessee's appeal in part and dismissed...

ITAT allowed the assessee's appeal in part and dismissed Revenue's appeal. It held that amounts reflected in seized document BSIPL/01 represented investments of third parties and could not be treated as undisclosed sales or income u/s 69A; the document must be read as a whole and not selectively. Additions based solely on WhatsApp chats were deleted for want of corroborative evidence and on the footing that any presumption u/s 292C would arise, if at all, in the hands of the person from whose possession the chats originated. The Tribunal upheld deletion of additions on alleged bogus purchases, finding no extra profit, and deleted addition u/s 68 for unsecured loans, noting complete evidentiary support and subsequent repayment.

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