Business expenditure on job work charges cannot be rejected on suspicion when banking proof and corroborative evidence support genuineness.

Job work charges cannot be disallowed as bogus or non-genuine merely on suspicion where the assessee supports the claim with banking records, TDS details, income-tax returns, confirmations recorded under section 131, and other documentary evidence showing actual services and payment by account payee cheque. Doubts about the workers' infrastructure, signatures, or use of the assessee's premises are insufficient without material showing that payments were returned to the assessee. On the record, the assessee discharged its onus, the disallowance was unsustainable, and the Revenue's challenge failed.

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Issues: Whether the disallowance of job work charges was justified on the ground that the expenditure was bogus or non-genuine.

Analysis: The addition was based on doubts about the job workers' infrastructure, alleged mismatch in signatures, and the fact that the workers operated from the assessee's premises. Against this, the assessee produced bank records, TDS details, income-tax returns, confirmations recorded under section 131, and other documentary evidence showing that payments were made through account payee cheques and that the parties had rendered services. There was no material showing that any part of the payments had come back to the assessee. The disallowance rested on suspicion rather than conclusive evidence, and the appellate finding that the assessee had discharged its onus was supported by the record.

Conclusion: The disallowance of job work charges was not sustainable and was rightly deleted; the Revenue's challenge failed.

Ratio Decidendi: A claim for business expenditure cannot be disallowed merely on suspicion where the assessee produces substantial corroborative evidence of service, payment through banking channels, and tax deduction, and there is no evidence of any funds being returned.

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