Verification of purchase genuineness and supplier enquiries led to remand for fresh adjudication after condoning delay.

A short delay in filing the appeal was condoned on the basis of reasonable cause, and the appeal was admitted. The dispute on unverifiable purchases concerned documentary support such as invoices, GST returns, e-way bills, transport receipts, stock records and bank statements, but the record showed no independent enquiry from the suppliers under sections 131 or 133(6) of the Income-tax Act, 1961. As the genuineness of purchases, movement of goods, transportation trail, stock reconciliation and banking transactions required fuller verification, the addition and restricted disallowance were set aside and the matter was restored for fresh adjudication de novo after effective opportunity to the assessee.

---

---

Issues: (i) Whether the 4-day delay in filing the appeal deserved condonation; (ii) whether the addition arising from alleged unverifiable purchases and the restricted disallowance sustained at 8% could be finally adjudicated on the existing record, or the matter required fresh examination.

Issue (i): Whether the 4-day delay in filing the appeal deserved condonation.

Analysis: The delay was supported by a condonation application, and the reasons furnished were accepted as constituting reasonable cause. The delay was short, and the appeal was treated as fit for admission.

Conclusion: The delay was condoned and the appeal was admitted.

Issue (ii): Whether the addition arising from alleged unverifiable purchases and the restricted disallowance sustained at 8% could be finally adjudicated on the existing record, or the matter required fresh examination.

Analysis: The dispute centred on purchases from suppliers stated to be non-filers, with the assessment made on an estimated disallowance and the first appellate authority sustaining a reduced estimate. The record showed that documentary evidence such as invoices, GST returns, e-way bills, transport receipts, stock records and bank statements had been produced, but no independent enquiry under sections 131 or 133(6) of the Income-tax Act, 1961 had been undertaken from the suppliers. The matter depended on fuller verification of purchase genuineness, movement of goods, transportation trail, stock reconciliation and banking transactions, which had not been conclusively examined.

Conclusion: The addition and the restricted disallowance were set aside and the entire matter was restored to the Assessing Officer for fresh adjudication de novo after proper verification and after granting effective opportunity to the assessee.

Final Conclusion: The controversy was not decided on merits at this stage and was remitted for fresh decision by the Assessing Officer, with both appeals treated as allowed for statistical purposes.

---