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    <title>2025 (3) TMI 1543 - ITAT MUMBAI</title>
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    <description>Additions under section 69A could not be sustained where they rested only on a third-party WhatsApp chat, an image and that third party&#039;s statement, without independent corroboration from the assessee&#039;s premises or any live nexus to the assessee. The electronic material did not reliably identify the assessee, did not explain the alleged payments, and was not proved in the manner required for admissibility of electronic evidence. The assessee denied receipt of cash, no incriminating material was found in its search, and the Tribunal noted that proceedings under section 153C would have been the appropriate route if reliance was to be placed on third-party search material. The additions were deleted and the revenue&#039;s appeals failed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=464627</link>
      <description>Additions under section 69A could not be sustained where they rested only on a third-party WhatsApp chat, an image and that third party&#039;s statement, without independent corroboration from the assessee&#039;s premises or any live nexus to the assessee. The electronic material did not reliably identify the assessee, did not explain the alleged payments, and was not proved in the manner required for admissibility of electronic evidence. The assessee denied receipt of cash, no incriminating material was found in its search, and the Tribunal noted that proceedings under section 153C would have been the appropriate route if reliance was to be placed on third-party search material. The additions were deleted and the revenue&#039;s appeals failed.</description>
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      <pubDate>Fri, 07 Mar 2025 00:00:00 +0530</pubDate>
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