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Suspicion cannot replace proof where business expenditure is supported by a complete documentary trail and no adverse material shows inflation or non-business use. The assessee produced issue and receipt vouchers, labour bills and banking records, the books were not rejected, stock records showed no discrepancy, and the labour charges were consistent with the jewellery manufacturing business and accepted turnover. The contractors responded to notices under section 133(6), and there was no evidence that cash withdrawn by them was routed back to the assessee. In the absence of any specific finding of bogus expenditure, the ITAT deleted the ad hoc disallowance of labour charges in full.
Suspicion cannot replace proof where business expenditure is supported by a complete documentary trail and no adverse material shows inflation or non-business use. The assessee produced issue and receipt vouchers, labour bills and banking records, the books were not rejected, stock records showed no discrepancy, and the labour charges were consistent with the jewellery manufacturing business and accepted turnover. The contractors responded to notices under section 133(6), and there was no evidence that cash withdrawn by them was routed back to the assessee. In the absence of any specific finding of bogus expenditure, the ITAT deleted the ad hoc disallowance of labour charges in full.
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