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    <title>2025 (7) TMI 364 - ITAT DELHI</title>
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    <description>An addition under section 69A of the Income-tax Act could not be sustained where it was based only on WhatsApp messages and a seized digital photo from a mobile phone, because the electronic material was not accompanied by the certificate required under section 65B(4) of the Indian Evidence Act. The audited books and the third party&#039;s confirmed account did not corroborate the alleged cash entries, and no independent evidence proved actual payment or receipt of cash. In these circumstances, the digital material was treated as inadmissible secondary electronic evidence and could not, by itself, justify the addition, which was deleted in favour of the assessee.</description>
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      <description>An addition under section 69A of the Income-tax Act could not be sustained where it was based only on WhatsApp messages and a seized digital photo from a mobile phone, because the electronic material was not accompanied by the certificate required under section 65B(4) of the Indian Evidence Act. The audited books and the third party&#039;s confirmed account did not corroborate the alleged cash entries, and no independent evidence proved actual payment or receipt of cash. In these circumstances, the digital material was treated as inadmissible secondary electronic evidence and could not, by itself, justify the addition, which was deleted in favour of the assessee.</description>
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