https://www.taxtmi.com/caselaws?id=192956 Where the assessee claimed fabrication charges, the HC held that the assessee discharged its initial onus to prove genuineness by producing evidence of account-payee cheque payments, banker certificates, and a contemporaneous gate-pass/challan control system; the AO's addition, based merely on non-service of summons and without further enquiry, was treated as a mechanical and unsustainable inference of siphoning. Consequently, the deletion of the addition was upheld. On characterization, the HC held that even if disallowance were warranted, it could not be assessed as "income from other sources" but would fall, if at all, within business profits, impacting export deduction computation; the AO's head-of-income treatment was rejected, and the revenue appeal was dismissed for absence of any substantial question of law. en-us Tue, 11 Sep 2007 00:00:00 +0530 Mon, 05 Jan 2026 16:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=192956 Where the assessee claimed fabrication charges, the HC held that the assessee discharged its initial onus to prove genuineness by producing evidence of account-payee cheque payments, banker certificates, and a contemporaneous gate-pass/challan control system; the AO's addition, based merely on non-service of summons and without further enquiry, was treated as a mechanical and unsustainable inference of siphoning. Consequently, the deletion of the addition was upheld. On characterization, the HC held that even if disallowance were warranted, it could not be assessed as "income from other sources" but would fall, if at all, within business profits, impacting export deduction computation; the AO's head-of-income treatment was rejected, and the revenue appeal was dismissed for absence of any substantial question of law. Case-Laws Income Tax Tue, 11 Sep 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=192956