Mere suspicion of fraud or lower GP cannot trigger Section 145(3) or 40A(2)(b) disallowances

DCIT Vs Global Agro Corp (ITAT Delhi) No Defects, No Additions – From Bogus Sales to 40A(2)(b): AO’s Suspicion vs Evidence — ITAT Finds Books Reliable, Deletes All Additions  In this Revenue appeal against Global Agro Corp, a rice exporter, Tribunal examined multiple additions made by AO in assessment u/s 143(3). Assessee had filed return declaring income of ₹66.28 lakh. AO made four major additions: ₹1.57 crore as bogus cash sales u/s 68, ₹4.81 crore as trading addition by estimating higher GP, ₹1.90 crore disallowance of commission u/s 40A(2)(b), & ₹32.30 lakh disall...