WhatsApp Chats Alone Cannot Prove ₹23 Cr On-Money; Refurbishment Proposal Accepted & Addition U/s 69 Deleted

DCIT Vs Payal Khemka (ITAT Delhi) Search proceedings in the Khemka Group revealed WhatsApp chats discussing a proposed property deal at A-32, Westend Colony, Delhi with a tentative price split of “76/23”. Based solely on these chats, the AO concluded that ₹23 crore represented undisclosed cash consideration paid over and above the registered value of ₹76 crore and made addition u/s 69 r.w.s. 115BBE. However, the CIT(A) examined the entire seized material holistically—including draft agreement to sell, renovation cost estimates and a board resolution dated 10-04-2019—and held that �...