Section 69C Addition Deleted: No 65B Certificate for Pen Drive Evidence; Third-Party Documents Insufficient – ITAT Hyderabad

ACIT Vs Ramesh Babu Segu (ITAT Hyderabad) Addition u/s 69C Based on Seized Pen Drive Deleted – Digital Evidence Without Valid 65B Certificate Inadmissible – Third-Party Documents Cannot Sustain Addition – ITAT Hyderabad Search in Polisetty Somasundaram Group led to issuance of notice u/s 153C to the assessee alleging cash payments of ₹1.10 crore based solely on data extracted from a seized pen drive and certain receipt copies. The AO treated the alleged payment as unexplained expenditure u/s 69C. However, CIT(A) deleted the addition observing that the receipts did not relate to the rel...