https://www.taxtmi.com/caselaws?id=789193 Section 69C can be invoked only where actual expenditure is shown to have been incurred and its source remains unexplained; it cannot sustain an addition merely because third parties do not respond or compliance is incomplete when the assessee substantiates the payments through agreements, invoices, ledger accounts, bank statements, TDS records and confirmations. Likewise, where GST-based material does not show any actual payment, claim of input tax credit or corresponding expenditure, no addition is made on that basis. On the facts, the first appellate authority's deletion of both additions was upheld because the Revenue failed to rebut the documentary evidence and factual findings. en-us Mon, 30 Mar 2026 00:00:00 +0530 Sat, 04 Apr 2026 08:53:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789193 Section 69C can be invoked only where actual expenditure is shown to have been incurred and its source remains unexplained; it cannot sustain an addition merely because third parties do not respond or compliance is incomplete when the assessee substantiates the payments through agreements, invoices, ledger accounts, bank statements, TDS records and confirmations. Likewise, where GST-based material does not show any actual payment, claim of input tax credit or corresponding expenditure, no addition is made on that basis. On the facts, the first appellate authority's deletion of both additions was upheld because the Revenue failed to rebut the documentary evidence and factual findings. Case-Laws Income Tax Mon, 30 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789193