https://www.taxtmi.com/caselaws?id=768680 ITAT Mumbai dismissed revenue's appeal challenging CIT(A)'s deletion of additions under sections 69A and 69C. The AO made additions based on WhatsApp images and documents found in phones/possession of third parties (personal assistant and HR employee). ITAT held that abstract documents without corroboration are "dumb documents" and cannot support additions. For section 69A, physical possession of unexplained money must be established, which was absent. Third-party statements that were retracted and not confronted with assessee cannot form basis for additions. AO failed to conduct proper enquiries or bring corroborating evidence. All additions were deleted as they relied on uncorroborated evidence from third parties. en-us Mon, 07 Apr 2025 00:00:00 +0530 Fri, 11 Apr 2025 08:40:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768680 ITAT Mumbai dismissed revenue's appeal challenging CIT(A)'s deletion of additions under sections 69A and 69C. The AO made additions based on WhatsApp images and documents found in phones/possession of third parties (personal assistant and HR employee). ITAT held that abstract documents without corroboration are "dumb documents" and cannot support additions. For section 69A, physical possession of unexplained money must be established, which was absent. Third-party statements that were retracted and not confronted with assessee cannot form basis for additions. AO failed to conduct proper enquiries or bring corroborating evidence. All additions were deleted as they relied on uncorroborated evidence from third parties. Case-Laws Income Tax Mon, 07 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768680