https://www.taxtmi.com/caselaws?id=461517 Additions based solely on electronic images from third-party mobile devices require compliance with section 65B of the Indian Evidence Act and independent corroboration linking the material to the assessee. The Tribunal treated the presumptions under sections 132(4A) and 292C as rebuttable and confined to the person from whose possession the material was found. Where the assessee's name did not appear on the electronic record and no reliable independent evidence supported the entries, third-party statements and WhatsApp-type extracts could not by themselves sustain additions under sections 69A and 69C. On that basis, the disputed additions were held unsustainable and the deletion of the larger section 69C addition was upheld. en-us Wed, 12 Feb 2025 00:00:00 +0530 Thu, 10 Apr 2025 19:26:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461517 Additions based solely on electronic images from third-party mobile devices require compliance with section 65B of the Indian Evidence Act and independent corroboration linking the material to the assessee. The Tribunal treated the presumptions under sections 132(4A) and 292C as rebuttable and confined to the person from whose possession the material was found. Where the assessee's name did not appear on the electronic record and no reliable independent evidence supported the entries, third-party statements and WhatsApp-type extracts could not by themselves sustain additions under sections 69A and 69C. On that basis, the disputed additions were held unsustainable and the deletion of the larger section 69C addition was upheld. Case-Laws Income Tax Wed, 12 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461517