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The HC upheld the Tribunal's decision that purchases under section 69C could not be treated as bogus despite unverifiable sources. The assessee substantiated the purchases through daily stock registers and production records (RG-23A and RG-23C), verified by the auditor and included in the TAR. Although notices under section 133(6) issued to the other party remained uncomplied and the party was not found at the recorded address, these facts were not disclosed to the assessee prior to the assessment order. Given the transactions were seven years old and the possibility of address changes, the AO did not dispute these circumstances. Consequently, the HC affirmed that the AO could not invoke section 69C, confirming the legitimacy of the purchases and rejecting the claim of bogus transactions.
The HC upheld the Tribunal's decision that purchases under section 69C could not be treated as bogus despite unverifiable sources. The assessee substantiated the purchases through daily stock registers and production records (RG-23A and RG-23C), verified by the auditor and included in the TAR. Although notices under section 133(6) issued to the other party remained uncomplied and the party was not found at the recorded address, these facts were not disclosed to the assessee prior to the assessment order. Given the transactions were seven years old and the possibility of address changes, the AO did not dispute these circumstances. Consequently, the HC affirmed that the AO could not invoke section 69C, confirming the legitimacy of the purchases and rejecting the claim of bogus transactions.
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