Third-Party iPhone Notes Not Enough: ITAT Mumbai Deletes ₹2 Cr Addition

ACIT Vs Jayesh Umakant Manania (ITAT Mumbai) ₹2 Cr Cash Addition Crumbles: Third-Party iPhone Notes, No Corroboration, No 65B—ITAT Mumbai Upholds Deletion In a reassessment framed u/s 147 r.w.s. 143(3), AO made addition of ₹2,00,00,000/- u/s 69A alleging unexplained cash paid for booking flats in “Vivaria”, solely on the basis of images/loose notings extracted from the iPhone of a third party (Shri Pankaj Goshar) during search/survey in connected cases. Assessee consistently denied any cash payment, stated no flat was booked in AY 2012-13, pointed out that all later transactions were...