Delay in filing appeal by 427 days due to health issues of an employee who was entrusted with income-tax compliance matters, must be condoned, since assessee does not gain anything by causing the delay. The appeal must be decided on merits.

On merits, it was held that an assessee cannot be required to prove a negative. When the assessee had, right from the beginning, stated that he had not made any purchases from the entity which was alleged to be an entity engaged in issuing fake bills, no addition under section 69C could be made, since the AO had not brought any material on record to show that such purchases were in fact made.