Uncorroborated digital files, unproven entries can't justify tax additions - SC affirms inadmissibility of electronic data sans supporting proof.

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....Digital images and Excel files found on partner's phone cannot be relied upon for making additions u/s 69C for unexplained expenditure. Loose papers and documents not corroborated by other evidence are considered dumb documents inadmissible as evidence. Mere entries in seized documents without proof of actual transactions cannot justify additions. Presumptions of imports based solely on electronic files without supporting materials are invalid. Additions made by the Assessing Officer solely relying on such uncorroborated electronic data were rightly deleted by the Tribunal following judicial precedents.....