Time limits for search-based assessments are a self-contained code; extension applies only with a transfer pricing reference, otherwise late orders ar...
Disallowance of purchases under section 37 was challenged where the assessee produced invoices, bank statements showing payments through banking channels, supplier confirmations and GST returns; the Tribunal held that production of these documents discharged the assessee's primary onus and, absent affirmative contrary material from the revenue proving suppliers non-existent or payments returned as cashback, the AO/first appellate authority could not draw an adverse inference to disallow entire purchases. Reliance on precedent supporting that complete disallowance is impermissible when supporting documents are furnished; disallowance deleted.
Disallowance of purchases under section 37 was challenged where the assessee produced invoices, bank statements showing payments through banking channels, supplier confirmations and GST returns; the Tribunal held that production of these documents discharged the assessee's primary onus and, absent affirmative contrary material from the revenue proving suppliers non-existent or payments returned as cashback, the AO/first appellate authority could not draw an adverse inference to disallow entire purchases. Reliance on precedent supporting that complete disallowance is impermissible when supporting documents are furnished; disallowance deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
