Dumb Documents & WhatsApp Chats Don’t Create Income – ITAT Quashes 153C, Deletes ₹22.5 Cr Addition

Raghav Kumar Vs ACIT (ITAT Delhi) These appeals arose from search-based assessments initiated u/s 153C against Assessee based on WhatsApp chats  &  photos of envelopes allegedly found in the mobile phone of a third party (Mr. Praveen Kumar Jain) during search on the Hans Group. AO presumed that Assessee had given cash loan of ₹22.50 Cr to Mahagun India Pvt. Ltd.  &  received assured interest @12%,  &  accordingly made additions u/s 69 (unexplained investment)  &  u/s 69A (cash interest). Assessee denied any such transaction, pointed out that his name did not even appe...