LEKCON INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(2), HYDERABAD

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ITA 1725/HYD/2025Status: DisposedITAT Hyderabad21 January 2026AY 2018-1935 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the document was digital evidence seized without adhering to the mandatory procedures of Section 65B of the Indian Evidence Act and the Digital Evidence Investigation Manual. Furthermore, the document was considered a 'dumb document' lacking specific details, rendering the AO's interpretation and subsequent additions unsustainable.

What were the facts?

During a search operation, a document (Page No. 39) was found in the WhatsApp messages of an employee. The Assessing Officer (AO) interpreted this document as evidence of the assessee providing cash loans and earning interest, making additions based on this interpretation. The CIT(A) sustained these additions.

What were the issues?

Validity of additions made based on digital evidence (WhatsApp message) without proper certification and corroboration, and whether a 'dumb document' can form the basis for tax additions.

Which sections of the Income-tax Act were involved?

Section 132,Section 68,Section 69C,Section 292C,Section 115BBE,Section 65B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Hyderabad “B” Bench, Hyderabad

आदेशकी प्रनतनलनप अग्रेनर्त/ Copy of the order forwarded to:-

1. 1. निर्धाररती/The Assessee : 1. M/s. Lekcon Infrastructure Private Limited, 3- 6-9/12, Narsingi Heights, Rajendra Nagar Mandal, Hyderabad – 500089, Telangana.

2. Shri Purushotham Naidu Lekkala, 3-6-9/12, Narsingi, Manchirevula, Hyderabad, K.v. Rangareddy – 500089, Telangana. 2. रधजस्व/ The Revenue : The ACIT/DCIT, Central Circle – 3(2), Hyderabad.

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