Documentary evidence of purchases sustains claimed inputs where revenue fails to rebut, leading to deletion of bogus-purchase additions.

Where claimed purchases were supported by sample invoices, e-way bills, account-payee cheque evidence, ledger entries and other documentary material, and revenue produced no rebuttal showing cash withdrawals, substitution or grey-market dealings, the addition for alleged bogus purchases was held unsustainable; the tribunal applied the earlier identical precedent in favour of the taxpayer and deleted the addition, allowing the appeal on merits. The operative effect is that documentary substantiation meeting the burden to demonstrate genuine purchases, absent contrary evidential material from revenue, will result in deletion of disputed disallowances for bogus purchases.

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Issues: (i) Whether the addition of Rs. 40,76,476 (3.65% of purchases from M/s R.K. Polymers) sustained by the CIT(A) on account of alleged bogus purchases is sustainable in law.

Analysis: The assessee produced sample purchase invoices, e-way bills, bank statements showing account-payee cheque payments, ledger entries and other documentary material substantiating the purchases from M/s R.K. Polymers. The revenue failed to produce material to rebut the documentary evidence or to show cash withdrawals or other facts establishing substitution or grey-market purchases. The declared sales were not disputed by the assessing officer. The tribunal examined the documentary record and followed the tribunal's earlier decision in the assessee's own case on identical facts, applying that precedent to the present appeal.

Conclusion: The addition of Rs. 40,76,476 on account of alleged bogus purchases is deleted and the assessee's appeal is allowed on merits in respect of this issue (in favour of the appellant).

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