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ITAT upheld that additions under section 69C were predicated on non-availability and doubtful identity of five suppliers, lack of evidence of delivery and commercial substance, and unexamined GST input tax credit (ITC) implications. The Tribunal restored the matter to the Assessing Officer for de novo adjudication limited to reconciling ITC claimed under the GST law in respect of the impugned purchases, including obtaining GST return and ITC status of the five suppliers from GST authorities if necessary, and examining how any denial of ITC affects commercial rationality and the assessee's claimed transactions. Appeal of the Revenue allowed for statistical purposes.
ITAT upheld that additions under section 69C were predicated on non-availability and doubtful identity of five suppliers, lack of evidence of delivery and commercial substance, and unexamined GST input tax credit (ITC) implications. The Tribunal restored the matter to the Assessing Officer for de novo adjudication limited to reconciling ITC claimed under the GST law in respect of the impugned purchases, including obtaining GST return and ITC status of the five suppliers from GST authorities if necessary, and examining how any denial of ITC affects commercial rationality and the assessee's claimed transactions. Appeal of the Revenue allowed for statistical purposes.
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