What did the Tribunal hold?

The Tribunal held that the WhatsApp chat did not provide evidence of an actual cash payment of Rs. 5 lakhs. The assessee's explanation of the chat being mere business enquiries was found to be more plausible.

The assessee's income was enhanced by Rs. 5,00,000/- by the AO based on a WhatsApp chat. The assessee contended that the chat was related to business enquiries and lacked corroborative evidence for the addition.

What were the issues?

Whether a WhatsApp chat, without corroborative evidence, can be the sole basis for making an addition to the assessee's income.

Tistabene Retails LLP, Jaipur vs DCIT | s.250 | ITAT Jaipur 2026

Income Tax Appellate Tribunal, JAIPUR BENCHES, “SMC” BENCH, JAIPUR

For Appellant: CA &

Hearing: 14.07.2026Pronounced: 16.07.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, “SMC” BENCH, JAIPUR BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER ITA No. 149/JPR/2026 (Assessment Year:2021-22)

Tistabene Retails LLP Vs. DCIT 344-A, Near Bees Dukan, Central Circle 4 Adarsh Nagar, Jaipur Jaipur �थायीलेखासं./जीआइआरसं./PAN/GIR No:AALFT 2070 N Appellant .. Respondent Appellant by : Sh. S. R. Sharma, CA & Sh. Rajnikant Batra, CA Respondent by : Mrs. Aarti Rawat, JCIT Date of Hearing 14.07.2026 Date of Pronouncement 16.07.2026 O R D E R The present appeal has been filed by the assessee against the order passed by the Office of the Commissioner of Income Tax Appeal, CIT(A), Jaipur-05 (hereinafter referred to as “Ld. CIT(A)”), dated 25.11.2025 under Section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”).

The assessee in this appeal has taken following grounds of appeal:-

P a g e | 2 ITA No. 149/JPR/2026 Tistabene Retails LLP 1. That on the facts and in the circumstances of the case, the learned CIT(A) is wrong, unjust and has erred in law in confirming addition of Rs. 5,00,000/- made by the learned AO to the declared income of the appellant firm on account of WhatsApp chat inventoried on Page No. 1 to 9 of Exhibit-1 of Party A-13 after rejecting submission of the appellant that impugned addition is based on misappreciation of facts and without any corroborative evidence. 2. That the appellant craves permission to add to or amend to any of the above grounds of appeal or to withdraw any of them. The appellant may during course of hearing may add, amend or withdraw any of above ground of appeal, if considered necessary.

The solitary issue in the present appeal relates to addition made to the income of the assessee of Rs.5 lakhs, on account of some information from whatsapp’s chat allegedly revealing the assessee to have made payment of the said amount in cash to an entity and the source of the same remaining unexplained.The contents of the whatsapp chat are reproduced at page 4 of the assessment order as under:

P a g e | 3 ITA No. 149/JPR/2026 Tistabene Retails LLP 4. The orders of the authorities below reveal this to be the only reason for making addition of Rs.5 lakhs to the income of the assessee The assessee, however , I have noted repeatedly contended that the chats were in relation to business enquiries made by, and with M/s. Rudra Inc., Mumbai, which was a business customer of the assessee.

I have gone through the contents of the chat and it is abundantly clear, that it makes no mention of cash of Rs.5 lakhs having been actually paid by the assessee. It is only a discussion of some payment details,to be made but not actually made. I do not agree therefore with the Revenue authorities that any inference of the assessee actually having paid Rs.5 lakhs to any party concerned can be drawn from the contents of the whatsapp chat of the assessee. In fact, the assessee’s explanation that the chat was mere business enquiries made, appears to be more plausible. 6. The Revenue has not come out with any other evidence, revealing cash payment having been made, in lieu of the, said whatsapp chat.

Therefore, I have no hesitation in holding that, the whatsapp chat could not have been the basis for making any addition on account of cash payment made by the assessee to any party concerned. The addition, therefore, made of Rs. 5 lacs is directed to be deleted.

P a g e | 4 ITA No. 149/JPR/2026 Tistabene Retails LLP 8. In effect, the appeal of the assessee is allowed. Order pronounced in the Open Court on 16.07.2026

Sd/- (Annapurna Gupta) ACCOUNTANT MEMBER Dated 16.07.2026 Mittali, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT By Order, Asst. Registrar ITAT, Jaipur

TISTABENE RETAILS LLP,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, JAIPUR

What did the Tribunal hold?

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