The assessee had declared purchases which were treated by the Assessing Officer as sham/non-genuine on the ground that the suppliers did not respond to notices under section 133(6) and certain GST registrations were cancelled/suspended. An addition of Rs.12,73,85,064 was made under section 69C read with section 115BBE. The CIT(A) confirmed the addition. The Tribunal deleted the addition after considering the books of account, purchase invoices, banking-channel payments and other evidence, observing that the sales were accepted and the books were not rejected under section 145(3). The High Court held that once the sales were accepted, the corresponding purchases could not be disbelieved or disallowed in entirety, particularly when the assessee had furnished supporting evidence and the Tribunal had recorded findings on appreciation of the material. The findings were findings of fact and no substantial question of law arose. The Revenue’s appeal was accordingly dismissed. (AY. 2021-22) (ITAT No. 147 of 2026 dt. 22-09-2026)