https://www.taxtmi.com/caselaws?id=784544 The dominant issue was whether revision under s.263 was justified where the AO, after finding purchase expenditure to be bogus, disallowed it under s.37(1) instead of invoking s.69C read with s.115BBE. The Tribunal held that s.37(1) concerns allowability based on commercial expediency, and no such controversy existed once the AO concluded that the goods were never received and the assessee failed to evidence receipt. Section 69C applies where expenditure is claimed but the assessee gives no satisfactory explanation of its source; those conditions were met, making the assessment order erroneous and prejudicial to the Revenue. The revisionary directions were upheld and the assessee's appeal was dismissed. en-us Wed, 31 Dec 2025 00:00:00 +0530 Wed, 07 Jan 2026 08:03:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784544 The dominant issue was whether revision under s.263 was justified where the AO, after finding purchase expenditure to be bogus, disallowed it under s.37(1) instead of invoking s.69C read with s.115BBE. The Tribunal held that s.37(1) concerns allowability based on commercial expediency, and no such controversy existed once the AO concluded that the goods were never received and the assessee failed to evidence receipt. Section 69C applies where expenditure is claimed but the assessee gives no satisfactory explanation of its source; those conditions were met, making the assessment order erroneous and prejudicial to the Revenue. The revisionary directions were upheld and the assessee's appeal was dismissed. Case-Laws Income Tax Wed, 31 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784544