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Additions under s.69A for alleged unexplained bank deposits and under s.69C for alleged unexplained cash purchases were examined in light of documentary evidence supporting purchases from farmers through a government-regulated APMC mandi. The assessee produced mandi certificates evidencing payment of statutory mandi and development charges and furnished Form 6R substantiating the purchases. Since the purchases were routed through a government body and were corroborated by contemporaneous records, the genuineness of the purchases could not be doubted and the presumption of unexplained expenditure was not attracted. Consequently, deletion of the s.69C additions was upheld and the appeal of the revenue was dismissed. - ITAT
Additions under s.69A for alleged unexplained bank deposits and under s.69C for alleged unexplained cash purchases were examined in light of documentary evidence supporting purchases from farmers through a government-regulated APMC mandi. The assessee produced mandi certificates evidencing payment of statutory mandi and development charges and furnished Form 6R substantiating the purchases. Since the purchases were routed through a government body and were corroborated by contemporaneous records, the genuineness of the purchases could not be doubted and the presumption of unexplained expenditure was not attracted. Consequently, deletion of the s.69C additions was upheld and the appeal of the revenue was dismissed. - ITAT
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