WhatsApp Chats ≠ Unexplained Money – U/s 69A & 115BBE Crumble Without Cash or Ownership

DCIT Vs Udit Jain (ITAT Delhi) ITAT Delhi dismissed the Revenue’s appeal for AY 2023-24 in Udit Jain, affirming CIT(A)’s deletion of a hefty ₹1.30 crore addition u/s 69A r.w.s. 115BBE, which was made solely on the basis of WhatsApp chats allegedly indicating receipt of sale proceeds of a Dubai property. The Tribunal recorded that a search u/s 132 yielded no recovery of cash, foreign currency, jewellery or any valuable article from the assessee. The entire addition rested on uncorroborated WhatsApp conversations extracted from the assessee’s mobile phone. Crucially, the Dubai property w...