Unexplained expenditure additions fail when contemporaneous records substantiate services and returned purchases create no income impact.

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....Contemporaneous invoices, GST returns, bank statements and ledger accounts can substantiate labour and manpower expenditure where payments pass through banking channels, tax is deducted at source, and transactions appear in GST records and audited accounts. A vendor's failure to respond to a notice, particularly after being struck off, does not by itself establish that expenditure is unexplained when the supporting evidence remains unrebutted and no further enquiry is undertaken. Purchases included in closing stock and returned in the following year do not affect income where no supplier payment or expenditure claim is made and related GST input is reversed. On these facts, both additions for unexplained expenditure were deleted.....