TaxTMI Login
AI Drafter - (New and Powerful) ✕
Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
Just a moment...
AI Drafter - (New and Powerful) ✕ Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
Press 'Enter' to add multiple search terms. Rules for Better Search
Use comma for multiple locations.
---------------- For section wise search only -----------------
Accuracy Level ~ 90%
of 
Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
All Case Laws
of Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
All Case Laws
Note
Bookmark
Share
Don't have an account? Register Here
of Press 'Enter' after typing page number.
Issues: Whether the addition made under section 69C on account of alleged bogus purchases could be sustained when the assessee produced purchase invoices, transport records, bank payments, GST-linked evidence and stock-related material, but the supplier's statement was used without effective cross-examination or corroboration.
Analysis: The assessee had placed on record documentary material showing the movement and receipt of goods, payments through banking channels, GST-related records and contemporaneous purchase evidence. The books of account were not rejected and no independent discrepancy in the trading results or stock position was established. The addition rested substantially on the supplier's denial of transactions, but no corroborative enquiry displaced the assessee's evidence and the opportunity of confronting the maker of the statement was not effectively afforded. In such circumstances, section 69C, which is directed to unexplained expenditure and its source, could not be applied merely on suspicion or on an untested third-party statement.
Conclusion: The addition under section 69C was not sustainable and the deletion made by the first appellate authority was upheld.
Ratio Decidendi: Where purchase transactions are reflected in the regular books, supported by banking and documentary evidence, and the books are not rejected, an addition under section 69C cannot be made merely on the basis of an uncorroborated third-party statement without effective confrontation or independent adverse material.
TaxTMI 
