Section 69 addition basis WhatsApp chats untenable sans source device/Evidence Act certificate: ITAT Mumbai

DCIT Vs Niru Dhiren Shah (ITAT Mumbai) Facts: 1. The assessee, Shri Niru Dhiren Shah, filed his return of income for A.Y. 2022–23 declaring total income of Rs. 30,50,500. A search and seizure operation under section 132 was carried out on 27.10.2021, wherein certain documents and electronic data were found at premises of parties connected to a purchaser of property allegedly transacted with the assessee. Subsequently, the case was taken up for scrutiny. The Assessing Officer completed the assessment under section 143(3) and determined total income at Rs. 3,47,15,985, making substantial addit...