Section 10A and related deductions: Tribunal rejects separate-undertaking claim, but allows loss set-off, ESOP cost and foreign tax credit in principl...
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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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