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Alleged bogus purchases, unexplained expenditure and trial-balance gross-profit adjustments held unsupported; assessment additions deleted for taxpayer

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Full Text of the Document

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....Whether purchases were bogus and income could be estimated: The Tribunal found that purchase and sale transactions occurred under excise supervision, permits supported sales, detailed procurement and production records were maintained, and AO relied only on loose papers/Tally from an ex-employee without confronting suppliers or independent corroboration; legal basis-additions cannot rest on presumption/conjecture and on uncorroborated third-party material. Outcome: additions for alleged bogus purchases deleted. Whether unexplained expenditure u/s 69C and witness evidence sustained: absence of opportunity to cross-examine and reliance on tamperable third-party data meant additions were invalid; outcome: deleted. Whether gross-profit addition from a dubious trial balance: TB was unreliable/dumb document; outcome: deletion. - ITAT....