Bogus turnover addition requires corroborative evidence linking transactions to the assessee; GST data alone is insufficient.

An addition treating alleged bogus turnover as unaccounted sales cannot stand without independent and corroborative material linking the impugned transactions to the assessee. The ITAT found that the Revenue relied only on GST information, while no inquiry established a nexus with the assessee's bank account or business activity, and the possibility of PAN misuse for GST registration was not rebutted. In the absence of proof that the sales were actually carried out by the assessee, the estimated profit addition at 8% was not sustainable. The deletion of the addition was upheld.

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Issues: Whether the addition made on account of alleged bogus turnover in the name of M/s Anmol Trading, treated as the assessee's unaccounted sales and taxed by applying an 8% profit rate, was sustainable in the absence of corroborative evidence linking the transactions to the assessee.

Analysis: The Revenue failed to rebut the finding that the assessee's PAN may have been misused for obtaining GST registration and that no independent inquiry established a nexus between the alleged bogus turnover and the assessee's bank account or business activity. The assessment was based only on information from the GST authorities, while no material was brought on record to prove that the impugned sales were actually carried out by the assessee. In the absence of corroborative evidence, the addition could not be sustained.

Conclusion: The deletion of the addition was upheld and the issue was decided in favour of the assessee.

Ratio Decidendi: An addition based on alleged bogus turnover cannot be sustained unless the Revenue establishes, by independent and corroborative material, a direct nexus between the impugned transactions and the assessee.

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