Proof of actual payment is essential for VAT, CST and Chapter VIA deductions; unverified claims were disallowed.

A deduction or allowance dependent on actual payment requires credible, verifiable evidence, and the assessee bears the burden of proof. The Tribunal accepted that VAT and CST payments under section 43B were not substantiated because bank statements or VAT authority confirmation were not produced, despite reliance on returns, bank seals and a no due certificate, so the disallowance was upheld. For Chapter VIA claims, including section 80C, the assessee also failed to prove LIC premium and tuition fee payments, so that disallowance was likewise sustained.

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Issues: (i) Whether the disallowance of VAT and CST payments under section 43B was sustainable in the absence of satisfactory evidence of actual payment; (ii) Whether the disallowance of the deduction claimed under Chapter VIA, including section 80C, was justified for want of proof.

Issue (i): Whether the disallowance of VAT and CST payments under section 43B was sustainable in the absence of satisfactory evidence of actual payment.

Analysis: The assessee relied on VAT returns, bank seals and a no due certificate, but did not produce corresponding bank statements or any supporting certificate from the VAT authorities. The material on record did not establish actual payment through banking channels, and the claim remained unverified despite the information received by the Department regarding fake challans. The Tribunal accepted the finding that the assessee failed to substantiate payment of the liability in the manner required for allowance under section 43B.

Conclusion: The disallowance of VAT and CST payments was upheld, against the assessee.

Issue (ii): Whether the disallowance of the deduction claimed under Chapter VIA, including section 80C, was justified for want of proof.

Analysis: The assessee did not furnish evidence of payment for the LIC premium and tuition fee claimed under section 80C, nor was the claim otherwise proved before the authorities. The onus to establish entitlement to the deduction was not discharged, and the claim therefore remained unsubstantiated.

Conclusion: The disallowance of the deduction claimed under Chapter VIA was upheld, against the assessee.

Final Conclusion: The Tribunal sustained the additions made in assessment and declined to grant any relief to the assessee on either disputed claim.

Ratio Decidendi: A deduction or allowance dependent on actual payment must be supported by credible evidence, and the assessee bears the burden of proving the claim with verifiable material.

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