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    <title>2025 (12) TMI 1166 - ITAT MUMBAI</title>
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    <description>The dominant issue was whether disallowance of expenses under s. 37 on the allegation of bogus purchases could rest solely on a retracted third-party statement alleging invoice accommodation and cash generation without delivery. The Tribunal held that the Act does not permit additions based only on such statements absent corroborative material, and that the assessee had produced contemporaneous documentary evidence supporting the expenditure which the AO failed to rebut with any specific adverse finding. It was also noted that no purchases were shown from the alleged accommodation provider, which was engaged in transport activity. The disallowance/addition was deleted and the appeal was decided against the revenue.</description>
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      <title>2025 (12) TMI 1166 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=783626</link>
      <description>The dominant issue was whether disallowance of expenses under s. 37 on the allegation of bogus purchases could rest solely on a retracted third-party statement alleging invoice accommodation and cash generation without delivery. The Tribunal held that the Act does not permit additions based only on such statements absent corroborative material, and that the assessee had produced contemporaneous documentary evidence supporting the expenditure which the AO failed to rebut with any specific adverse finding. It was also noted that no purchases were shown from the alleged accommodation provider, which was engaged in transport activity. The disallowance/addition was deleted and the appeal was decided against the revenue.</description>
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