Addition u/s. 68 merely based on SMS or WhatsApp messages without corroborative evidence unsustained

Atul Tantia Vs DCIT (ITAT Kolkata)

ITAT Kolkata held that addition towards undisclosed income u/s 68 of the Income Tax Act merely based on the SMS or WhatsApp messages without any corroborative evidences is unsustainable in law.

Facts- A search and seizure u/s 132 of the Act was conducted on 12/09/2017 on GPT Group of cases including the assessee. During the course of search and seizure, mobile data was retrieved and printout of SMS were taken out from the mobile of Shri Atul Tantia. As per the mobile

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