आदेश/ORDER

PER PADMAVATHY.S, A.M:

This appeal by the assessee is against the order of the Principal Commissioner of Income Tax, Chennai-3 (in short "PCIT") passed u/s. 263 of the Income Tax Act, 1961 (in short "the Act") dated 12.03.2025 for Assessment Year (AY) 2021-22. The assessee raised the following grounds of appeal:

“1. The order of the learned Assessing Officer Is Contrary to law and Facts and Circumstance of the case.

2. The Ld AO failed to appreciate the evidence submitted in course of assessment proceedings and assessed certain purchase as not genuine and assessed as unexplained expenditure.

3. The LD AO without considering the evidence in support of the expenditure submitted, failed to see the merit of the same sighting time limit while passing the assessment order.

4. Reason behind the disallowance of expenditure was non filing of ITR by suppliers, non response to the 133(6) notice and presumptions that supplies were not made, though e-way bill was submitted during the proceedings along with invoice copies, ledger account, bank statement.

5. After the advent of GST and online portal to claim ITC, when the outward supplies are duly recorded, supplier is bound to discharge the