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“bogus purchases”

DisallowancesSection 69CSection 69C9,532 judgments

The decision most relied on for bogus purchases is CIT v. Bholanath Poly Fab. Pvt. Ltd. (355 ITR 290), cited in 712 judgments on BharatTax.

Leading authorities on 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.

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.

CIT v. Simit P. Seth
38 Taxmann.com 385 · 2013 · High Court
278
citing judgments

When an assessee obtains accommodation bills for purchases but the corresponding sales are genuine, the addition to income is limited to the gross profit margin embedded in such purchases. This principle acknowledges that the underlying sales were real, but profit was suppressed through bogus invoices.

CIT v. Vijay M. Mistry Construction Ltd.
355 ITR 498 · 2013 · High Court
252
citing judgments

In cases of alleged bogus or hawala purchases where the existence of transactions is not entirely denied, only the profit element embedded in such purchases, and not the entire purchase price, can be added to the assessee's income. The focus is on determining a reasonable profit percentage for such additions.

Judgments citing bogus purchases

Final Copy (I) Pvt Ltd, Mumbai vs. ITO Ward 6(3)(1), Mumbai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1192/MUM/2020[2010-11]Status: DisposedITAT Mumbai25 Mar 2022AY 2010-11

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadalefinal Copy (I) Pvt Ltd Vs. Ito, Ward-6(3)(1) C/18, First Floor Royal Room No. 524, 5Th Industrial Estate, Sb Floor, Aayakar Naigaon Cross Road, Bhavan, Mk Marg, Wadala, Mumbai – Mumbai – 400020. 400031. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacf7458 Appellant .. Respondent Appellant By : Mr.Gunjan Kakkad.Ar Respondent By : Mr.Rajesh Kumar Yadav.Dr Date Of Hearing 22.03.2022 Date Of Pronouncement 25.03.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The Commissioner Of Income Tax (Appeals)-12, Mumbai Passed 144 & 250 Of The Act. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Mr.Gunjan Kakkad.ARFor Respondent: Mr.Rajesh Kumar Yadav.DR
Section 142(1)Section 143(1)Section 143(3)Section 144Section 148Section 36(2)

required to be quashed. 3. The Hon. CIT(A) erred in confirming the addition of Rs.2,24,640/-, made on account of alleged bogus purchases debited to the profit and loss account of the appellant, not appreciating that the concerned purchases were genuine purchases duly supported by substantial evidences ... addition may kindly be deleted. 4. The Hon. CIT(A) erred in upholding the addition of Rs.2,24,640/-, made on account of alleged bogus purchases, without affording your appellant with any opportunity to cross examine the source of such adverse evidence, thereby breaching the silent principles of equity, fairplay

ACIT 26 (2), Mumbai vs. Perfect Garments Processors, Mumbai

In the result, for ay 2009-10 appeal of the learned

ITA 6591/MUM/2019[2009-10]Status: DisposedITAT Mumbai25 Mar 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri RA Dhyani, DRFor Respondent: Shri Vimal Punmiya, AR
Section 143(3)Section 148

circumstances of the case and in law, the Ld. CIT (A)) has erred in restricting the disallowance of 12.5% of the total of bogus purchase transaction instead of 100% of the total amount of bogus purchase made by the AO for the A. Y. 2009-10?" B. Whether ... considering that the addition was made on the basis of information received from DIT(Inv.) and Sales Tex Department, Maharashtra with regard to bogus purchase made by the assessee from dealers without supply of actual goods?" ITA Nos.6590,6591,6580 & 6579/Mum/2019 Perfecr Garments Processors

ACIT 26 (2), Mumbai vs. Perfect Garments Processors, Mumbai

In the result, for ay 2009-10 appeal of the learned

ITA 6590/MUM/2019[2010-11]Status: DisposedITAT Mumbai25 Mar 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri RA Dhyani, DRFor Respondent: Shri Vimal Punmiya, AR
Section 143(3)Section 148

circumstances of the case and in law, the Ld. CIT (A)) has erred in restricting the disallowance of 12.5% of the total of bogus purchase transaction instead of 100% of the total amount of bogus purchase made by the AO for the A. Y. 2009-10?" B. Whether ... considering that the addition was made on the basis of information received from DIT(Inv.) and Sales Tex Department, Maharashtra with regard to bogus purchase made by the assessee from dealers without supply of actual goods?" ITA Nos.6590,6591,6580 & 6579/Mum/2019 Perfecr Garments Processors

Perfect Garments Processors, Mumbai vs. ITO 29 (2)(5), Mumbai

In the result, for ay 2009-10 appeal of the learned

ITA 6580/MUM/2019[2009-10]Status: DisposedITAT Mumbai25 Mar 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri RA Dhyani, DRFor Respondent: Shri Vimal Punmiya, AR
Section 143(3)Section 148

circumstances of the case and in law, the Ld. CIT (A)) has erred in restricting the disallowance of 12.5% of the total of bogus purchase transaction instead of 100% of the total amount of bogus purchase made by the AO for the A. Y. 2009-10?" B. Whether ... considering that the addition was made on the basis of information received from DIT(Inv.) and Sales Tex Department, Maharashtra with regard to bogus purchase made by the assessee from dealers without supply of actual goods?" ITA Nos.6590,6591,6580 & 6579/Mum/2019 Perfecr Garments Processors

Perfect Garment Processors, Mumbai vs. ITO 29(2)(5), Mumbai

In the result, for ay 2009-10 appeal of the learned

ITA 6579/MUM/2019[2010-11]Status: DisposedITAT Mumbai25 Mar 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri RA Dhyani, DRFor Respondent: Shri Vimal Punmiya, AR
Section 143(3)Section 148

circumstances of the case and in law, the Ld. CIT (A)) has erred in restricting the disallowance of 12.5% of the total of bogus purchase transaction instead of 100% of the total amount of bogus purchase made by the AO for the A. Y. 2009-10?" B. Whether ... considering that the addition was made on the basis of information received from DIT(Inv.) and Sales Tex Department, Maharashtra with regard to bogus purchase made by the assessee from dealers without supply of actual goods?" ITA Nos.6590,6591,6580 & 6579/Mum/2019 Perfecr Garments Processors

Hemant M. Mehta HUF, Mumbai vs. ACIT 33 (2), Mumbai

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

ITA 6483/MUM/2018[2008-09]Status: DisposedITAT Mumbai25 Mar 2022AY 2008-09

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadalehemant M Mehta Huf Vs. Acit – 33(2), A-307/308, Ekta Room No. 302, 3Rd Terrace, Dahanuru Floor, C-11, Wadi, Kandivili (W), Pratyakshakr Bhavan, Maharashtra – 400 067 Bandra-Kurla Complex, Bandra (E) Mumbai - 400051 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aachh8909M Appellant .. Respondent Appellant By : Shri Ashok Bansal & Shri Ajay Daga.Ar Respondent By : Ms. Neena Jeph. Dr Date Of Hearing 14.03.2022 Date Of Pronouncement 22.03.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The Commissioner Of Income Tax (Appeals)-45, Mumbai Passed U/S 143(3) R.W.S 147 & 250 Of The Act. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri Ashok Bansal &For Respondent: Ms. Neena Jeph. DR
Section 143(2)Section 143(3)Section 145(3)Section 148Section 292

Tribunal vide order dated 06.12.2019 has partly allowed the appeal of the assessee with directions to the Assessing officer in respect of bogus purchases and gross profit ratio. Subsequently, the assessee has filed the Miscellaneous application in MA No.246/Mum/2021 that there is a mistake apparent on record that

Asst CIT Cen Cir 8(4), Mumbai vs. D B M Geotechnics & Constructions P.Ltd, Mumbai

In the result, this appeal is dismissed

ITA 6225/MUM/2018[2014-15]Status: DisposedITAT Mumbai25 Mar 2022AY 2014-15
Section 143(3)

erred in deleting the Assessing Officer to restrict the addition of Rs.26,11,780/- to the extent of 12% only made on account of bogus purchase despite of the facts that the assessee has failed to substantiate his claim of purchase”. (2) “On the facts and in the circumstances ... dated 16th January, 2017 vide SLP No. 769 of 2017 wherein the decision of High Court for addition of entire income on account of bogus purchases had been confirmed.” Assessment Year: 2014-15 Page 2 of 3 3. We find that a coordinate bench of this tribunal, in the case

Asst CIT Cen Cir 8(4), Mumbai vs. D B M Geotechnics & Constructions P.Ltd, Mumbai

In the result, this appeal is dismissed

ITA 6224/MUM/2018[2012-13]Status: HeardITAT Mumbai25 Mar 2022AY 2012-13
Section 143(3)

erred in directing the Assessing Officer to restrict the addition of Rs. 8,505/- to the extent of 12% only made on account of bogus purchase despite of the facts that the assessee has failed to substantiate his claim of purchase”. (5) “On the facts and in the circumstances ... dated 16th January, 2017 vide SLP No. 769 of 2017 wherein the decision of High Court for addition of entire income on account of bogus purchases had been confirmed.” 3. We find that a coordinate bench of this tribunal, in the case of Rollon Hardware India

Income-Tax Officer, Ward - 14 (3), Pune vs. Jeevan Popatlal Bhaliya, Pune

In the result, appeal of the Revenue is allowed for statistical purposes

ITA 1635/PUN/2017[2009-10]Status: DisposedITAT Pune24 Mar 2022AY 2009-10
For Appellant: Shri S.P. WalimbeFor Respondent: Shri Abhay Avchat
Section 144Section 147

following grounds:- i) Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in allowing the bogus purchases as well as the bogus sales made by the assessee and also there was no proof of bogus sales.? ii) Whether on the facts ... case and in law, the Ld. CIT(A) is justified in his action when the Gujrat High Court has held that the bogus purchase was disallowed when the same has been held as bogus and the order of the high court was confirmed by Hon'ble Supreme Court of India

Shri Pawan F. Birawat, Surat vs. The Income Tax Officer, Ward-3(1)(5), Surat

In the result, the grounds of appeal raised by assessee is partly allowed

ITA 277/SRT/2018[2013-14]Status: DisposedITAT Surat23 Mar 2022AY 2013-14

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 132Section 254(1)

facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in estimating the profit @ 12.50% on alleged bogus purchase, without appreciating the fact that the payment was made through cross account payee cheque and the same goods were subsequently sold and quantity is tallied ... entities managed by Sh. Bhanwarlal Jain Group. Bhanwarlal Jain Group is engaged in providing accommodation entry by various bogus concern. The assessee has shown bogus purchase of Rs. 32,60,47,961/- from various companies/ firms and proprietorship concern which were managed by Sh. Bhanwarlal Jain Group. The Assessing Officer

Shri Pawan F. Birawat, Surat vs. The Income Tax Officer, Ward-2(3)(8), Surat

In the result, the grounds of appeal raised by assessee is partly allowed

ITA 1388/AHD/2017[2012-13]Status: DisposedITAT Surat23 Mar 2022AY 2012-13

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 132Section 254(1)

facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in estimating the profit @ 12.50% on alleged bogus purchase, without appreciating the fact that the payment was made through cross account payee cheque and the same goods were subsequently sold and quantity is tallied ... entities managed by Sh. Bhanwarlal Jain Group. Bhanwarlal Jain Group is engaged in providing accommodation entry by various bogus concern. The assessee has shown bogus purchase of Rs. 32,60,47,961/- from various companies/ firms and proprietorship concern which were managed by Sh. Bhanwarlal Jain Group. The Assessing Officer

The ITO, Ward-3(1)(5), Surat vs. Shri Pawan Fojmal Birawat, Surat

In the result, the grounds of appeal raised by assessee is partly allowed

ITA 1155/AHD/2017[2012-13]Status: DisposedITAT Surat23 Mar 2022AY 2012-13

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 132Section 254(1)

facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in estimating the profit @ 12.50% on alleged bogus purchase, without appreciating the fact that the payment was made through cross account payee cheque and the same goods were subsequently sold and quantity is tallied ... entities managed by Sh. Bhanwarlal Jain Group. Bhanwarlal Jain Group is engaged in providing accommodation entry by various bogus concern. The assessee has shown bogus purchase of Rs. 32,60,47,961/- from various companies/ firms and proprietorship concern which were managed by Sh. Bhanwarlal Jain Group. The Assessing Officer

ITO Ward-3(1), Mumbai vs. Bharat Chunilal Doshi, Mumbai

In the result, this appeal filed by the revenue stands dismissed

ITA 591/MUM/2021[2009-10]Status: DisposedITAT Mumbai23 Mar 2022AY 2009-10

Bench: Shri Shamim Yahya

Section 133(6)Section 145(3)Section 148Section 69C

Thane erred in deleting the addition of Rs. 8.94.261/- out of the total addition of Rs. 10,96,581/- made on account of bogus purchases, despite holding that the purchases were not genuine and the assessee failed to prove genuineness of the transactions. 2.On the facts and in the circumstances ... received the bills as well as goods for manufacturing purpose and also paid the amount by account payee cross cheques and there is no bogus purchase or hawala transaction. The assessee further contended that no sales were likely to be affected if there were no purchases. The assessee further stated

ITO 9(3)(4), Mumbai vs. M/S Goapla Krishna Papers Pvt Ltd, Mumbai

In the result, appeal by the revenue stands dismissed

ITA 536/MUM/2020[2010-11]Status: DisposedITAT Mumbai23 Mar 2022AY 2010-11

Bench: Shri Shamim Yahya

Section 133(6)Section 143Section 143(1)Section 143(3)Section 147Section 263

assessment was done by processing u/s. 143(1). Subsequently, assessment was reopened. The reopening was on account of information from sales tax department for bogus purchases amounting to Rs. 4,89,51,357/-. The AO proceeded to hold that notice u/s.133(6) were issued to parties from whom assessee ... noted that copies of delivery challans, bills of transport of goods were not produced. Hence, AO added 12.5% as estimated profit on the bogus purchases and added the same. 4. Upon assessees appeal, ld.CIT(A) quashed the reopening. He noted that in this case after proper enquiry proceedings

Jagdish B Pisharody, Navi Mumbai vs. Asst CIT 28(1), Mumbai

In the result, the appeal filed by the assessee is dismissed

ITA 1304/MUM/2020[2011]Status: DisposedITAT Mumbai23 Mar 2022

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2011-12 Jagdish B. Pisharody, Asst. Commissioner Of Income Tax- 303, Radhe Krishna Chs Ltd., 28(1), 306, 3Rd Floor, Tower No. 6, Vashi Sector 16A, Plot No. 15, Palm Vs. Beach Road, Sanpada, Railway Station, Commercial Navi Mumbai-400705. Complex, Vashi, Navi Mumbai-400703 Pan No. Amlpp 9429 P Appellant Respondent

For Appellant: NoneFor Respondent: Mr. S.N. Kabra, DR
Section 133(6)Section 69C

erred in affirming with the Ld. Assessing Officer and adding ₹28,36,462/- at 12.5% of total purchases (₹.2,26,91,701/-) alleged as bogus purchases without appreciating Jagdish B. Pisharody 2 the fact that the purchase of goods was made from the genuine buyers to whom payment was made ... bills were obtained from those two parties. Accordingly, he in the reassessment order Jagdish B. Pisharody 3 dated 08/03/2016, added back 12.5% of the bogus purchases of ₹2,26,91,701 as unexplained expenditure under section 69C of the Act, which was worked out to ₹28,36,462/-. On further

Salem Steel Industries, Mumbai vs. Income Tax Officer-19(3)(2), Mumbai

In the result, this appeal by the assessee stands dismissed

ITA 6190/MUM/2019[2011-12]Status: DisposedITAT Mumbai23 Mar 2022AY 2011-12

dated 10.8.2018 pertains to A.Y. 2011-12. 2. The issue raised is that learned CIT(A) erred in sustaining addition @ 12.5% for bogus purchases. 3. At the outset it is noted that there is delay of 338 days in filing this appeal. Despite notice on several occasions, none appeared

Assistant Commissioner of Income-Tax, Circle - 2, Solapur vs. M/S. Beekay Enterprises, Solapur

In the result, the legal ground taken in the assessee’s cross objection which goes to the root of the matter is allowed and the ground on merits therefore, becomes academic in nature

ITA 1687/PUN/2017[2010-11]Status: DisposedITAT Pune22 Mar 2022AY 2010-11
For Appellant: Shri S.N. PuranikFor Respondent: Shri Deepak Garg
Section 133Section 143(3)Section 148Section 68Section 69C

case and in law, the Ld. CIT(A)-7, Pune is justified in restricting addition at Rs. 69,21,245/- being 20% of alleged bogus purchases from Hawala dealers of Rs. 3,46,06,232/- on account to profit out of alleged bogus purchases amounting ... Pune is erred in restricting the disallowance @ C.O. 41/PUN/2019 Beekay Enterprises A.Y. 2010-11 20% of bogus purchases from Hawala traders being profit element in bogus purchases of Rs. 3,46,06,232/- which A.O. disallowed u/s 68/69C being bogus expenditure incurred to reduce the profit in the business

ITO Ward 2 (3), Thane vs. Shri. Chandrashekhar Nathalal Trivedi, Mira Road

In the result, appeal filed by the assessee is partly allowed and appeal filed by the learned assessing officer is dismissed

ITA 7432/MUM/2019[2010-11]Status: DisposedITAT Mumbai22 Mar 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Chandrasekhar Nathalal Trivedi Income Tax Officer, 704, Akash Ganga, Near Jangid Ward 2(5), Thane Room No. 13, B-Wing, 6Th Circle, Mtnl Road, Mira Road Vs. East, Thane-401107 Floor, Ashar It Park, Wagle Industrial Estate, Road No.16- Z, Thane(W)-400604 (Appellant) (Respondent) Pan No. Aaapt3199H Income Tax Officer, 2(5), Room Chandrasekhar Nathalal Trivedi No. 13, B-Wing, 6Th Floor, 704, Akash Ganga, Near Jangid Ashar It Park, Wagle Industrial Circle, Mtnl Road, Mira Road Vs. Estate, Road No.16-Z, East, Thane-401107 Thane(W)-400604

Section 143(1)Section 143(3)Section 147

7432/Mum/2019 Chandrashekhar Nathalal Trivedi; AY 10-11 2. The Ld. CIT(A) has erred in law and in facts confirming the disallowance of alleged bogus purchases at Rs.3,28,19,832/- being 12.5% of total purchases of Rs.26,25,58,657/- in the hands of the appellant.” 05. Brief facts ... beneficiaries of the accommodation entries. Moreover, Sales Tax Department, Maharashtra gave the names and address of certain persons who have provided entries of bogus purchase to a large number of taxpayers, assessee is also one of the beneficiaries. The providers of accommodation entries have also filed affidavit before Sales

Chandrashekhar Nathalal Trivedi, Mira Road vs. ITO Ward 2 (5), Thane

In the result, appeal filed by the assessee is partly allowed and appeal filed by the learned assessing officer is dismissed

ITA 6605/MUM/2019[2010-11]Status: DisposedITAT Mumbai22 Mar 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Chandrasekhar Nathalal Trivedi Income Tax Officer, 704, Akash Ganga, Near Jangid Ward 2(5), Thane Room No. 13, B-Wing, 6Th Circle, Mtnl Road, Mira Road Vs. East, Thane-401107 Floor, Ashar It Park, Wagle Industrial Estate, Road No.16- Z, Thane(W)-400604 (Appellant) (Respondent) Pan No. Aaapt3199H Income Tax Officer, 2(5), Room Chandrasekhar Nathalal Trivedi No. 13, B-Wing, 6Th Floor, 704, Akash Ganga, Near Jangid Ashar It Park, Wagle Industrial Circle, Mtnl Road, Mira Road Vs. Estate, Road No.16-Z, East, Thane-401107 Thane(W)-400604

Section 143(1)Section 143(3)Section 147

7432/Mum/2019 Chandrashekhar Nathalal Trivedi; AY 10-11 2. The Ld. CIT(A) has erred in law and in facts confirming the disallowance of alleged bogus purchases at Rs.3,28,19,832/- being 12.5% of total purchases of Rs.26,25,58,657/- in the hands of the appellant.” 05. Brief facts ... beneficiaries of the accommodation entries. Moreover, Sales Tax Department, Maharashtra gave the names and address of certain persons who have provided entries of bogus purchase to a large number of taxpayers, assessee is also one of the beneficiaries. The providers of accommodation entries have also filed affidavit before Sales

Sh. Sumit Kumar Bagra, New Delhi vs. ITO, New Delhi

In the result, the appeal is dismissed and enhanced

ITA 623/DEL/2014[2006-07]Status: DisposedITAT Delhi22 Mar 2022AY 2006-07

Bench: Shri Kul Bharat[Assessment Year: 2006-07

Section 143(3)Section 271Section 40A(3)

treated as bogus. The addition made by the Assessing Officer is therefore enhanced to Rs.44,65,738/-. Penalty under section 271(1)(c) for bogus purchases is initiated separately for filing inaccurate particulars of the income. Without prejudice to above, the payments in respect of the above purchases has been