Suppressed outward supplies require transaction-wise verification and reasoned findings before diary entries can support tax and penalty determinations.
Case-Laws
GST
Suppressed outward supplies cannot be established by aggregate diary figures without a demonstrable factual basis. A reasoned determination requires identification and entry-wise examination of relevant transactions, reconciliation with accounts and statutory returns, and consideration of the taxpayer's explanations and supporting evidence. Missing invoices or books during investigation do not alone establish suppression; subsequently produced invoices and claims of disclosure in GSTR-1 also require verification. Consequential tax and penalty must be determined through a reasoned decision after a reasonable opportunity of hearing.
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