Section 68 Misapplied

This ruling reinforces a critical limitation on revenue powers:

Suspicion, even if strong, cannot substitute evidence.

The Tribunal emphasized that:

• Section 68 requires books of account + unexplained credit

• In presumptive taxation (Section 44AD), books may not exist at all

• Additions under Section 69C cannot be made on pure presumption (e.g., assumed commission payments)

The case is a strong rebuttal to the increasingly common practice of treating bank entries and invoices as insufficient without physical corroboration.