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ITAT upheld that additions under section 69C could not be conclusively determined on the record and remanded the matter to the AO for fresh verification and adjudication. The tribunal accepted that the assessee paid GST, interest and penalty and submitted delivery challans, ledger and bank statements, but found absence of stock registers and incontrovertible proof of physical receipt undermining the claim of genuine purchases. Reliance on a spouse's favourable order and on precedents was rejected as distinguishable. Consequently, the appeal was partly allowed for statistical purposes only, with directions to the AO to examine actual movement of goods, genuineness of purchases and correct tax treatment (including assessment under section 115BBE versus regular business income).
ITAT upheld that additions under section 69C could not be conclusively determined on the record and remanded the matter to the AO for fresh verification and adjudication. The tribunal accepted that the assessee paid GST, interest and penalty and submitted delivery challans, ledger and bank statements, but found absence of stock registers and incontrovertible proof of physical receipt undermining the claim of genuine purchases. Reliance on a spouse's favourable order and on precedents was rejected as distinguishable. Consequently, the appeal was partly allowed for statistical purposes only, with directions to the AO to examine actual movement of goods, genuineness of purchases and correct tax treatment (including assessment under section 115BBE versus regular business income).
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