Facts
The assessee challenged the disallowance of purchases amounting to Rs. 1,35,66,404/- and ad hoc disallowances of certain expenses. The core issue was the genuineness of purchases from untraceable parties and the substantiation of various business expenses.
Held
The Tribunal ruled that the assessee failed to discharge the onus of proving the genuineness of the impugned purchases. For expenses, it was held that while wholly and exclusively business expenses are allowable, the assessee must substantiate them, and the quantum of disallowance for certain expenses was reduced.
Key Issues
Genuineness of purchases from untraceable parties and justification for ad hoc disallowances of expenses.
Sections Cited
143(3), 133(6), 68, 69C
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Before: SHRI SANDEEP GOSAIN & SHRI PRABHASH SHANKAR
PER PRABHASH SHANKAR [A.M.] :- The present appeal arising from the appellate order dated 16.06.2025 is filed by the assessee against the order passed by the Learned Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre, Delhi [hereinafter referred to as “CIT(A)