Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
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The Tribunal held that sales to the assessee's partnership firm were genuine because the alleged bogus-sales finding rested only on third-party statements, while GST returns, Form 26AS, ledger accounts and bank evidence consistently supported the transactions. It noted that corresponding purchases were accepted, stock reduced on sale, and no defect was found in the documentary records or any incriminating material in search. In the absence of material showing the transactions were sham, the Revenue could not estimate commission or profit at 8% on assumptions and conjecture. The addition based on alleged bogus sales was deleted and the appeal was partly allowed.
The Tribunal held that sales to the assessee's partnership firm were genuine because the alleged bogus-sales finding rested only on third-party statements, while GST returns, Form 26AS, ledger accounts and bank evidence consistently supported the transactions. It noted that corresponding purchases were accepted, stock reduced on sale, and no defect was found in the documentary records or any incriminating material in search. In the absence of material showing the transactions were sham, the Revenue could not estimate commission or profit at 8% on assumptions and conjecture. The addition based on alleged bogus sales was deleted and the appeal was partly allowed.
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