Digital Evidence Authentication Failures Prevent Income-Tax Additions, While Mandatory Post-Search Reassessment Governs Covered Assessment Years

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....Electronic evidence lacking valid certification, proven device control, seizure records, chain of custody, hash value or corroboration cannot support income-tax additions. Digital ledger entries representing dummy, contra, adjustment or opening balances, without proof of actual receipt, do not justify unexplained-credit additions; unauthenticated WhatsApp chats alone likewise cannot establish unexplained money. Routine leased-premises repairs and annual software upgrades are revenue expenditure, whereas multi-period licence costs require apportionment under accrual and matching principles. Post-search assessments for covered preceding years must follow the prescribed reassessment procedure; use of regular scrutiny assessment is jurisdictionally defective.....