Section 69C: Unexplained Business Purchases Cannot Be Partially Allowed Through Profit Estimation When Source Remains Unproven

HC ruled in favor of revenue department, reversing lower authorities' decision to apply 12.5% estimation on bogus purchases. Assessee failed to explain source of expenditure for alleged purchases during reassessment proceedings. Though assessee provided limited details of sundry debtors, creditors, and stocks before CIT(A), they did not establish transaction genuineness. Before Tribunal, assessee only sought percentage-based estimation without proving purchase authenticity. HC held AO justified in adding entire amount of unexplained expenditure under Section 69C, as partial allowance through profit estimation contradicts statutory provisions. Revenue's appeal allowed, rejecting assessee's claim of having discharged burden of proof regarding purchase genuineness and payment sources. .....

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