PURUSHOTHAM NAIDU LEKKALA,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(2), HYDERABAD, HYDERABAD

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ITA 1726/HYD/2025Status: DisposedITAT Hyderabad21 January 2026AY 2018-1935 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the additions made by the AO could not be sustained as the seized digital evidence (WhatsApp chat) was not supported by a certificate under Section 65B(4) of the Indian Evidence Act, 1872, and lacked corroborative evidence.

What were the facts?

During a search operation, a document (page 39) from WhatsApp messages of an employee was seized. The Assessing Officer (AO) used this document to make additions towards unexplained cash loans and interest, totaling Rs. 9,76,20,000/-.

What were the issues?

The primary issue was the admissibility of digital evidence (WhatsApp chats) without a Section 65B certificate and the validity of additions made based on such evidence.

Which sections of the Income-tax Act were involved?

Section 68,Section 69C,Section 132,Section 153A,Section 115BBE,Section 65B

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

For Appellant: Shri H. Srinivasulu, C.A
For Respondent: Shri P. Dhivahar, CIT-DR
Pronounced: 21.01.2026

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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