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2025 (10) TMI 1479

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.... of the case are that the case of the assessee was selected for scrutiny as it was noticed that the assessee had made substantial purchases from certain suppliers who were either non-filers of income tax returns, filed returns with abnormally low turnover, or whose GST registrations were either cancelled or suo motu suspended as per ADG (GST) data. Based on this information, the Assessing Officer formed a view that there was a possibility of the assessee booking bogus or inflated purchase expenses to reduce taxable profit, and accordingly, scrutiny proceedings were initiated by issue of statutory notices. During the course of assessment, the Assessing Officer issued notices under section 133(6) to the suppliers seeking verification of the t....

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....ancellation of their GST registrations, which are factors beyond the control of the assessee. Once sales have been accepted, the corresponding purchases cannot be disbelieved. It was further contended that the non-filing of income-tax returns or cancellation of GST registration by the suppliers cannot, by itself, make the assessee's purchases non-genuine, especially when payments were made through proper banking channels and quantitative details were duly maintained. 5. The learned DR supported the orders of the lower authorities, contending that the Assessing Officer had made the addition after providing sufficient opportunity and that the assessee failed to discharge the onus to prove the genuineness of purchases beyond doubt. 6. We....