Evidentiary support and cross-examination rights defeat additions based on WhatsApp chats, retracted statements, and presumptions.
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....WhatsApp messages used to support an alleged cash transaction were held insufficient without corroboration, so the related addition was deleted. Additions based on a retracted search statement and a third-party statement were also unsustainable where the assessee sought copies of material and cross-examination, but no proper evidentiary foundation or independent enquiry was made. Income already returned and taxed in the spouse's hands could not be taxed again as the assessee's undisclosed income. For agricultural income, the Tribunal accepted documentary support and upheld only a limited estimate rather than the full addition. Additions based on presumed agricultural income of family members were likewise rejected for want of evidence.....
TaxTMI