No Section 69C Addition Solely Based on WhatsApp Messages: ITAT Mumbai

ACIT Vs Prashant Prakash Nilawar (ITAT Mumbai)

Conclusion: Addition based on WhatsApp messages exchanged between the taxpayer and third parties, alleging undisclosed financial transactions was not justified as AO had simply relied on such material found from the premises of a third party and relied on third party statement to make addition without corroborating it with any kind of independent evidence and enquiry.

Held: In the instant case, premises of GNP Group were also covered during the search action on Rucha Group. During the said searc

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