https://www.taxtmi.com/caselaws?id=797389 Section 153(6) allows twelve months from the end of the month in which the appellate order is received or passed by the specified senior income-tax authority. Delivery of a Tribunal order to the Departmental Representative is treated as internal transmission, and without proof of delivery to the proper authority, limitation is not established. Purchases cannot be treated wholly as unexplained expenditure where VAT verification, stock and movement records, supplier existence, and corresponding sales substantiate them. Non-response by some suppliers to summons, without addressing that independent material, does not justify an addition of the entire purchase value; only suppressed profit may be estimated where supported. en-us Wed, 12 Aug 2026 00:00:00 +0530 Fri, 21 Aug 2026 08:28:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797389 Section 153(6) allows twelve months from the end of the month in which the appellate order is received or passed by the specified senior income-tax authority. Delivery of a Tribunal order to the Departmental Representative is treated as internal transmission, and without proof of delivery to the proper authority, limitation is not established. Purchases cannot be treated wholly as unexplained expenditure where VAT verification, stock and movement records, supplier existence, and corresponding sales substantiate them. Non-response by some suppliers to summons, without addressing that independent material, does not justify an addition of the entire purchase value; only suppressed profit may be estimated where supported. Case-Laws Income Tax Wed, 12 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797389