Bogus purchase additions fail where audited records, supplier confirmations and manufacturing-consumption evidence remain unrebutted.

Alleged bogus-purchase additions cannot rest on suspicion or a search statement where audited books, supplier confirmations and contemporaneous records establish genuine purchases and manufacturing consumption. The documented evidence included invoices, e-way bills, transport and weighment records, banking payments, GST compliance, stock and production records, and yield reconciliation. Suppliers directly confirmed the transactions, profitability remained consistent with prior performance, and no defects or evidentiary discrepancies were identified. The article notes that the estimated addition was deleted for both assessment years because no substantive contrary material supported the allegation.

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Issues: Whether an addition based on alleged bogus purchases could be sustained despite audited books, supplier confirmations and documentary evidence establishing the purchases and their consumption in manufacturing.

Analysis: The purchases were supported by regular audited books, invoices, e-way bills, transport records, weighment slips, banking-channel payments, GST records, stock and production records, and a yield reconciliation. The suppliers responded to notices under Section 133(6) of the Income-tax Act, 1961, directly confirming the transactions. The profitability results were consistent with the assessee's historical performance, and no defect in the books or discrepancy in the supporting evidence was identified. An estimated addition founded on suspicion and a search statement, without substantive contrary material, was unsustainable.

Conclusion: The addition sustained for alleged bogus purchases was deleted in favour of the assessee; the same conclusion applied to both assessment years.

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