Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
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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