Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
Recorded purchases supported by bills and vouchers, transport and FASTag data, banking-channel payments, and GST/TDS particulars were treated as genuine where the books were not rejected and no defect appeared in trading results or stock records. Reliance on a supplier's statement without effective cross-examination was insufficient. The source of expenditure principle was applied to state that unexplained expenditure provisions cannot be invoked merely because the supplier's authenticity is doubted when the payment source is explained from disclosed accounts. On these facts, the addition for alleged bogus purchases was deleted and the Revenue challenge failed.
Recorded purchases supported by bills and vouchers, transport and FASTag data, banking-channel payments, and GST/TDS particulars were treated as genuine where the books were not rejected and no defect appeared in trading results or stock records. Reliance on a supplier's statement without effective cross-examination was insufficient. The source of expenditure principle was applied to state that unexplained expenditure provisions cannot be invoked merely because the supplier's authenticity is doubted when the payment source is explained from disclosed accounts. On these facts, the addition for alleged bogus purchases was deleted and the Revenue challenge failed.
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