← All Phrases

“bogus purchases”

DisallowancesSection 69CSection 69C9,532 judgments

The decision most relied on for bogus purchases is CIT v. Simit P. Sheth (356 ITR 451), cited in 1,465 judgments on BharatTax.

Leading authorities on bogus purchases

CIT v. Simit P. Sheth
356 ITR 451 · 2013 · High Court
1,465
citing judgments

Additions for alleged bogus purchases should be restricted to the profit element, not the entire turnover. The profit element is often estimated at 12.5% of the purported bogus purchases.

CIT v. Bholanath Poly Fab. Pvt. Ltd.
355 ITR 290 · 2013 · High Court
712
citing judgments

If an assessee makes purchases from bogus parties, but the underlying goods are genuinely acquired and sold, only the profit margin embedded in such purchases, and not the entire value of the bogus purchases, should be added to the assessee's income.

Sanjay Oilcake Industries v. CIT
316 ITR 274 · 2009 · High Court
460
citing judgments

In cases of alleged bogus or unverifiable purchases, rather than disallowing the entire purchase value, a reasonable profit element or a proportionate percentage of the purchases should be added back to the assessee's income.

Vijay Proteins Ltd. v. Asst. CIT
58 ITD 428 · 1996 · ITAT
430
citing judgments

Where purchases are found to be non-genuine or fictitious, a reasonable disallowance of 25% of such purchases or the peak credit, whichever is higher, can be made. This is applied to address unexplained expenditure under Section 69C when actual goods are likely procured from the grey market.

CIT v. Odeon Builders Pvt. ltd.
418 ITR 315 · 2019 · Supreme Court
408
citing judgments

Income tax additions cannot be sustained merely on the basis of uncorroborated statements or allegations. The Revenue must bring on record sufficient material and allow the assessee to produce evidence to prove such additions.

CIT v. Nikunj Exim Enterprises Pvt. Ltd.
372 ITR 619 · 2015 · High Court
391
citing judgments

Transactions defying human probability cannot be applied to isolated purchases if sales are accepted as genuine, and purchases cannot be disallowed without considering the entire transaction and documentary evidence. Failure to produce parties in an assessment proceeding may not be fatal to the assessee.

Nikunj Eximp Enterprises v. CIT
216 Taxmann 171 · 2013 · High Court
325
citing judgments

Purchases may be treated as genuine even if the purchase parties are untraceable or not available for verification, as long as there is no specific evidence from the parties themselves denying the transactions or proving them to be bogus.

CIT v. Shyam R. Pawar
54 Taxmann.com 108 · 2015 · High Court
279
citing judgments

Transactions involving the purchase and sale of shares cannot be considered bogus where the assessee provides documentary evidence, unless the revenue brings substantial evidence on record to reject such proof. This principle is consistently applied in cases concerning claims of bogus long-term capital gains arising from penny stock transactions.

Judgments citing bogus purchases

Deputy Commissioner of Income Tax, Central Circle, Panaji vs. M/S Mohit Ispat Ltd., Kundaim

Appeal of the Revenue is PARTLY ALLOWED in aforestated terms

ITA 9/PAN/2020[2016-17]Status: DisposedITAT Panaji13 Oct 2026AY 2016-17

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2016-17 Dy. Commissioner Of Income Tax, Central Circle, Panaji, Goa. . . . . . . . Appellant V/S M/S Mohit Ispat Limited 339/340, Kundaim Industrial Estate, Goa-403115 Pan: Aaccm8154E . . . . . . . Respondent Represented Assessee By: Mr Shriniwas Naik & Narchiva Lotlikar [‘Ld. Ar’] Revenue By: Mr Naveen Kumar [‘Ld. Dr’] Date Of Conclusive Hearing : 04/02/2026 Date Of Pronouncement : 27/02/2026 Order Per G. D. Padmahshali; This Appeal Of The Revenue Instituted U/S 253(2) Of The Income-Tax Act, 1961 [‘The Act’] Challenges Order Dt. 04/10/2019 Passed U/S 250 Of The Act By The Commissioner Of Income Tax Appeals-2, Panaji Goa [‘Ld. Cit(A)’] Which In Turn Sprung From Order Of Assessment Dt. 30/12/2017 Passed U/S 143(3) Of The Act By Acit, Central Circle, Panaji Goa [‘Ld. Ao’] Anent To Assessment Year 2016-17.[‘Ay’]

For Appellant: Mr Shriniwas Naik & Narchiva Lotlikar [‘Ld. AR’]For Respondent: Mr Naveen Kumar [‘Ld. DR’]
Section 132Section 133ASection 139(1)Section 143(3)Section 246ASection 250Section 253Section 253(2)

coming to such magical ad-hoc declaration. It was further argued that the decision relied upon by the Ld. CIT(A) dealt with bogus purchases hence inapplicable. ITAT-Panaji Page 28 of 44 ACIT Vs M/s Mohit Ispat Limited ITA No. 009/PAN/2020 AY: 2016-17 24. The search was conducted ... decision of Ld. Co-ordinate bench in assessee’s own is concerned, the facts of that year were immensely distinguishable as it dealt with bogus purchase wherein the assessee to the satisfaction of the bench established the case for restricting the addition on such account to be accepted to profit

Rakesh H Mehta HUF, Mumbai vs. ACIT, CC-1(2), Pune

In the result, all the three appeals of the assessee are dismissed

ITA 1733/PUN/2024[2019-20]Status: DisposedITAT Pune15 Jul 2026AY 2019-20

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: NoneFor Respondent: Shri Arvind Desai
Section 132Section 132(4)Section 142(1)Section 250

concerned, ld. AO made addition of Rs.1,45,419/- on account of commission income being 1% on the alleged bogus purchases shown by the assessee at Rs.1,45,41,902/-. The ld.CIT(A) confirmed the addition made by the AO as the facts and circumstances for both the A.yrs ... these brokers at the desired location. As admitted by Shri Madhu Kalaskar, Shri Rakesh Mehta was one of these brokers who used to issue bogus purchase bills to BVG India in lieu of Commission. The amount received as sale consideration through banking channel used to be returned in cash

Rakesh H Mehta HUF, Mumbai vs. ACIT, CC-1(2), Pune

In the result, all the three appeals of the assessee are dismissed

ITA 1732/PUN/2024[2019-20]Status: DisposedITAT Pune15 Jul 2026AY 2019-20

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: NoneFor Respondent: Shri Arvind Desai
Section 132Section 132(4)Section 142(1)Section 250

concerned, ld. AO made addition of Rs.1,45,419/- on account of commission income being 1% on the alleged bogus purchases shown by the assessee at Rs.1,45,41,902/-. The ld.CIT(A) confirmed the addition made by the AO as the facts and circumstances for both the A.yrs ... these brokers at the desired location. As admitted by Shri Madhu Kalaskar, Shri Rakesh Mehta was one of these brokers who used to issue bogus purchase bills to BVG India in lieu of Commission. The amount received as sale consideration through banking channel used to be returned in cash

Rakesh H Mehta HUF, Mumbai vs. ACIT, CC-1(2), Pune

In the result, all the three appeals of the assessee are dismissed

ITA 1731/PUN/2024[2018-19]Status: DisposedITAT Pune15 Jul 2026AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: NoneFor Respondent: Shri Arvind Desai
Section 132Section 132(4)Section 142(1)Section 250

concerned, ld. AO made addition of Rs.1,45,419/- on account of commission income being 1% on the alleged bogus purchases shown by the assessee at Rs.1,45,41,902/-. The ld.CIT(A) confirmed the addition made by the AO as the facts and circumstances for both the A.yrs ... these brokers at the desired location. As admitted by Shri Madhu Kalaskar, Shri Rakesh Mehta was one of these brokers who used to issue bogus purchase bills to BVG India in lieu of Commission. The amount received as sale consideration through banking channel used to be returned in cash

Co-Operation Metals, Pune vs. ITO Ward 6(3), Pune

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2321/PUN/2024[2010-11]Status: DisposedITAT Pune21 Apr 2026AY 2010-11

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

hawala parties. 5. In appeal the Ld. CIT(A) / NFAC directed the Assessing Officer to restrict the addition to 18% of the said bogus purchases by observing as under: ITA Nos.2319 & 2271/PUN/2024 & Ors 6. Aggrieved with part relief granted by the Ld. CIT(A) / NFAC, the assessee as well ... deciding the GPM (gross profit margin) of 18% on alleged Hawala Purchases solely relying upon the information received from sales tax department indicating alleged bogus purchases made. The I-T authorities ought to have proceeded further for cross-examination of the suppliers/further probing of such suppliers, from whom the alleged

Co-Operation Metals, Pune vs. ITO Ward 6(3), Pune

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2320/PUN/2024[2011-12]Status: DisposedITAT Pune21 Apr 2026AY 2011-12

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

hawala parties. 5. In appeal the Ld. CIT(A) / NFAC directed the Assessing Officer to restrict the addition to 18% of the said bogus purchases by observing as under: ITA Nos.2319 & 2271/PUN/2024 & Ors 6. Aggrieved with part relief granted by the Ld. CIT(A) / NFAC, the assessee as well ... deciding the GPM (gross profit margin) of 18% on alleged Hawala Purchases solely relying upon the information received from sales tax department indicating alleged bogus purchases made. The I-T authorities ought to have proceeded further for cross-examination of the suppliers/further probing of such suppliers, from whom the alleged

Co-Operation Metals, Pune vs. ITO Ward 6(3), Pune

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2319/PUN/2024[2009-10]Status: DisposedITAT Pune21 Apr 2026AY 2009-10

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

hawala parties. 5. In appeal the Ld. CIT(A) / NFAC directed the Assessing Officer to restrict the addition to 18% of the said bogus purchases by observing as under: ITA Nos.2319 & 2271/PUN/2024 & Ors 6. Aggrieved with part relief granted by the Ld. CIT(A) / NFAC, the assessee as well ... deciding the GPM (gross profit margin) of 18% on alleged Hawala Purchases solely relying upon the information received from sales tax department indicating alleged bogus purchases made. The I-T authorities ought to have proceeded further for cross-examination of the suppliers/further probing of such suppliers, from whom the alleged

Income Tax Officer, Pune vs. Cooperation Metals, Pune

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2263/PUN/2024[2011-12]Status: DisposedITAT Pune21 Apr 2026AY 2011-12

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

hawala parties. 5. In appeal the Ld. CIT(A) / NFAC directed the Assessing Officer to restrict the addition to 18% of the said bogus purchases by observing as under: ITA Nos.2319 & 2271/PUN/2024 & Ors 6. Aggrieved with part relief granted by the Ld. CIT(A) / NFAC, the assessee as well ... deciding the GPM (gross profit margin) of 18% on alleged Hawala Purchases solely relying upon the information received from sales tax department indicating alleged bogus purchases made. The I-T authorities ought to have proceeded further for cross-examination of the suppliers/further probing of such suppliers, from whom the alleged

Income Tax Officer, Pune vs. Cooperation Metals, Pune

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2262/PUN/2024[2009-10]Status: DisposedITAT Pune21 Apr 2026AY 2009-10

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

hawala parties. 5. In appeal the Ld. CIT(A) / NFAC directed the Assessing Officer to restrict the addition to 18% of the said bogus purchases by observing as under: ITA Nos.2319 & 2271/PUN/2024 & Ors 6. Aggrieved with part relief granted by the Ld. CIT(A) / NFAC, the assessee as well ... deciding the GPM (gross profit margin) of 18% on alleged Hawala Purchases solely relying upon the information received from sales tax department indicating alleged bogus purchases made. The I-T authorities ought to have proceeded further for cross-examination of the suppliers/further probing of such suppliers, from whom the alleged

DCIT-13.3.2, Mumbai vs. Remi Sales and Engineering Limited, Mumbai

In the result, the appeal of the Revenue stands dismissed

ITA 9259/MUM/2025[2011-12]Status: DisposedITAT Mumbai21 Apr 2026AY 2011-12
Section 115JSection 143(1)Section 143(3)Section 147Section 69C

Revenue lies in the action of the learned CIT(A) in restricting the addition made under section 69C on account of alleged bogus purchases to 15% of the impugned purchases amounting to Rs.1,23,750/-, thereby sustaining an addition of only Rs.18,562/- as against 100% disallowance made

ITO 19.3.1, Mumbai vs. Sourabh Navalkishor Garg, Mumbai

In the result the appeals filed by the revenue for both years under consideration stands dismissed

ITA 5804/MUM/2025[2010-11]Status: DisposedITAT Mumbai21 Apr 2026AY 2010-11

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 148Section 37Section 68Section 74

issued u/s. 148 and order under appeal passed by ACIT, Circle 2, Ajmer is without jurisdiction, without appreciating the facts that assessee has claimed bogus purchases of Rs.5,04,94,046/- from M/s. Kotsons Impex Pvt Ltd., M/s. Shree Jalaram Enterprises and M/s. Excellent Diamonds Pvt Ltd., a Hawala Bogus ... facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the addition on account of bogus purchases of Rs.5,04,94,046/- made from M/s. Kotsons Impex Pvt Ltd., M/s. Shree Jalaram Enterprises and M/s. Excellent Diamonds Pvt Ltd., a Hawala Bogus Entry

Income Tax Officer, Pune vs. Cooperation Metals, Pune

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2271/PUN/2024[2010-11]Status: DisposedITAT Pune21 Apr 2026AY 2010-11

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

hawala parties. 5. In appeal the Ld. CIT(A) / NFAC directed the Assessing Officer to restrict the addition to 18% of the said bogus purchases by observing as under: ITA Nos.2319 & 2271/PUN/2024 & Ors 6. Aggrieved with part relief granted by the Ld. CIT(A) / NFAC, the assessee as well ... deciding the GPM (gross profit margin) of 18% on alleged Hawala Purchases solely relying upon the information received from sales tax department indicating alleged bogus purchases made. The I-T authorities ought to have proceeded further for cross-examination of the suppliers/further probing of such suppliers, from whom the alleged

ITO 19.3.1, Mumbai vs. Sourabh Navalkishor Garg, Mumbai

In the result the appeals filed by the revenue for both years under consideration stands dismissed

ITA 5803/MUM/2025[2009-10]Status: DisposedITAT Mumbai21 Apr 2026AY 2009-10

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 148Section 37Section 68Section 74

issued u/s. 148 and order under appeal passed by ACIT, Circle 2, Ajmer is without jurisdiction, without appreciating the facts that assessee has claimed bogus purchases of Rs.5,04,94,046/- from M/s. Kotsons Impex Pvt Ltd., M/s. Shree Jalaram Enterprises and M/s. Excellent Diamonds Pvt Ltd., a Hawala Bogus ... facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the addition on account of bogus purchases of Rs.5,04,94,046/- made from M/s. Kotsons Impex Pvt Ltd., M/s. Shree Jalaram Enterprises and M/s. Excellent Diamonds Pvt Ltd., a Hawala Bogus Entry

Hira Lal Gupta, Kolkata vs. I.T.O., Ward - 52(1), Kolkata

In the result, the appeal filed by the assessee is partly allowed

ITA 2077/KOL/2025[2018-2019]Status: DisposedITAT Kolkata17 Apr 2026AY 2018-2019

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 139(1)Section 142(1)Section 148Section 250

circumstances of the case the Ld. Assessing Officer has eared in disallowing a portion of Purchase of Rs.31,38,175/- on account of bogus purchases without proper verification. 2. That the Ld. Assessing Officer has failed to consider the fact that by disallowing the purchases, the gross profit rate ... Machinery and M/s. Dev Traders was Sh. Bittu Mondal and purchases made from Sh. Bittu Mondal were for ₹72,99,685/- only, the total bogus purchases were worked out at ₹1,25,52,701/-. The assessee had requested in response to the show cause notice citing various High Courts’ decisions

M/S. Perq Advertisings Pvt Ltd, Mumbai vs. DCIT, Circle 2(3)(1), Mumbai

ITA 76/MUM/2026[2010-11]Status: DisposedITAT Mumbai17 Apr 2026AY 2010-11
For Appellant: Shri Sameer G. DalalFor Respondent: Shri Virabhadra S. Mahajan
Section 133(6)Section 143(3)Section 147Section 271(1)(c)

read with Section 147 of the Act addition of INR.43,00,258/- was made in the hands of the Assessee in respect of alleged bogus purchases since the Assessee had failed to furnish corroborative documents. The profit element embedded alleged bogus purchases was computed at 14.60% of the alleged bogus ... INR.2,94,53,819/-. In the quantum appeal, the Learned CIT(A) vide Order dated 19/03/2019 reduced the addition to 12.5% of alleged bogus purchases. No further appeal was preferred by the appellant against the order of the Learned CIT (A) in quantum proceedings. 6. Thereafter, vide Penalty Order, dated

M/S. Perq Advertising Pvt Ltd, Mumbai vs. DCIT, Circle 2(3)(1), Mumbai

ITA 75/MUM/2026[2011-12]Status: DisposedITAT Mumbai17 Apr 2026AY 2011-12
For Appellant: Shri Sameer G. DalalFor Respondent: Shri Virabhadra S. Mahajan
Section 133(6)Section 143(3)Section 147Section 271(1)(c)

read with Section 147 of the Act addition of INR.43,00,258/- was made in the hands of the Assessee in respect of alleged bogus purchases since the Assessee had failed to furnish corroborative documents. The profit element embedded alleged bogus purchases was computed at 14.60% of the alleged bogus ... INR.2,94,53,819/-. In the quantum appeal, the Learned CIT(A) vide Order dated 19/03/2019 reduced the addition to 12.5% of alleged bogus purchases. No further appeal was preferred by the appellant against the order of the Learned CIT (A) in quantum proceedings. 6. Thereafter, vide Penalty Order, dated

DCIT, Central Circle-4(3), Kolkata vs. Balmukund Concast Private Limited, Patna

In the result, the appeals of the Revenue are dismissed and the appeal of the assessee is allowed

ITA 1893/KOL/2025[2023-24]Status: DisposedITAT Kolkata15 Apr 2026AY 2023-24

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Balmukund Concast Pvt. Ltd. Dcit, Cc 4(3) 108 Kalyani Complex, Exhibition Aaykar Bhawan, Kolkata-700069 Vs. Road, Patna-800001, Bihar West Bengal (Respondent) (Appellant) Pan No. Aaacb9503G

For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Dheeraj, DR
Section 115JSection 132Section 143(1)

based on surmises and conjectures. Based on the above discussion it is decided thatthe addition made of Rs.12,45,885/-. on account of bogus purchases @ 4% on the turnoverof Rs.3,11,47,131/- is to be deleted. Hence, the AO is directed to delete the addition ofRs.12,45,885/-. Therefore ... purchases were made from parties different than the parties entered in the books of account. On this account, AO has made addition for bogus purchases @ 25% of the purchases. This can only be said to be surmise. It is settled law that no addition is permissible on the basis

DCIT, Central Circle-4(3), Kolkata vs. Balmukund Concast Private Limited, Patna

In the result, the appeals of the Revenue are dismissed and the appeal of the assessee is allowed

ITA 1892/KOL/2025[2019-20]Status: DisposedITAT Kolkata15 Apr 2026AY 2019-20

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Balmukund Concast Pvt. Ltd. Dcit, Cc 4(3) 108 Kalyani Complex, Exhibition Aaykar Bhawan, Kolkata-700069 Vs. Road, Patna-800001, Bihar West Bengal (Respondent) (Appellant) Pan No. Aaacb9503G

For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Dheeraj, DR
Section 115JSection 132Section 143(1)

based on surmises and conjectures. Based on the above discussion it is decided thatthe addition made of Rs.12,45,885/-. on account of bogus purchases @ 4% on the turnoverof Rs.3,11,47,131/- is to be deleted. Hence, the AO is directed to delete the addition ofRs.12,45,885/-. Therefore ... purchases were made from parties different than the parties entered in the books of account. On this account, AO has made addition for bogus purchases @ 25% of the purchases. This can only be said to be surmise. It is settled law that no addition is permissible on the basis

Balmukund Concast Pvt. Ltd., Patna vs. DCIT, Central Circle 4(3), Kolkata

In the result, the appeals of the Revenue are dismissed and the appeal of the assessee is allowed

ITA 1380/KOL/2025[2023-2024]Status: DisposedITAT Kolkata15 Apr 2026AY 2023-2024

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Balmukund Concast Pvt. Ltd. Dcit, Cc 4(3) 108 Kalyani Complex, Exhibition Aaykar Bhawan, Kolkata-700069 Vs. Road, Patna-800001, Bihar West Bengal (Respondent) (Appellant) Pan No. Aaacb9503G

For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Dheeraj, DR
Section 115JSection 132Section 143(1)

based on surmises and conjectures. Based on the above discussion it is decided thatthe addition made of Rs.12,45,885/-. on account of bogus purchases @ 4% on the turnoverof Rs.3,11,47,131/- is to be deleted. Hence, the AO is directed to delete the addition ofRs.12,45,885/-. Therefore ... purchases were made from parties different than the parties entered in the books of account. On this account, AO has made addition for bogus purchases @ 25% of the purchases. This can only be said to be surmise. It is settled law that no addition is permissible on the basis

Vinod Kumar, New Delhi vs. DCIT, Circle-1(1)(1), Meerut

ITA 1311/DEL/2026[2018-19]Status: DisposedITAT Delhi15 Apr 2026AY 2018-19

Bench: Shri Satbeer Singh Godaraassessment Year: 2018-19 Vs. Deputy Sh. Vinod Kumar Commissioner C/O M/S Raj Kumar & Income Tax Circle-1(1)(1) Associates Aayakar Bldgi, Meerut, L-7A (Lgf), South Extension Uttar Pradesh Part-Ii New Delhi- 110049

Section 147

appellate’ discussions have made it clear as to in what manner the assessee’s payer; M/s Swastik Traders, had been engaged in providing such bogus purchases entries of agricultural produce. That being the case, I hereby uphold the impugned addition made in the assessee’s case in very terms