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Issues: Whether the addition made on account of alleged accommodation entries in the guise of bogus purchases could be sustained when the departmental portal information was uncorroborated and the alleged supplier denied any transaction with the assessee.
Analysis: The addition was founded only on information from the departmental Insight Portal. The assessee denied any transaction with the alleged supplier, and the notice under section 133(6) of the Income-tax Act, 1961 elicited a categorical denial from that supplier as well. No independent evidence such as purchase invoices, ledger accounts, bank trail, delivery documents, stock records, or incriminating material was brought on record to establish the existence of the alleged transaction. Mere information or suspicion could not substitute proof, and the Revenue failed to discharge the initial burden of establishing the foundational facts necessary to sustain the addition.
Conclusion: The addition was not sustainable and the deletion made by the first appellate authority was upheld.