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“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

ITO 27(1)(4), Mumbai vs. Shri Inderjeet Singh Bhabra, Mumbai

In the result this appeal filed by the revenue stands dismissed

ITA 3633/MUM/2019[2010-11]Status: DisposedITAT Mumbai21 Oct 2020AY 2010-11
Section 41(1)

from sales tax department that assessee has made purchases of Rs.1,56,000/- from bogus dealers. The Assessing Officer made 100% addition of the bogus purchases. 3. Upon assessee's appeal learned CIT-A has noted that the said purchases has been offered as income ... again. In view of these facts of the case I am in agreement with the submission of the appellant accordingly the addition of entire bogus purchase of Rs. 1,56,0007- is deleted. These grounds of appeal are 'Allowed.'” 4. Against above order revenue is in appeal before the ITAT

M/S.Sls Tubes Private Limited, Mumbai vs. Deputy Commissioner Income Tax Central Circle-2(3), Mumbai

In the result, both the appeals of the assessee and revenue are partly allowed

ITA 1305/MUM/2018[2009-10]Status: DisposedITAT Mumbai21 Oct 2020AY 2009-10

Bench: Shri Justice P P Bhatt & Shri M. Balaganesh, Am M/S. Hellios Tubealloys Pvt. Vs. Dcit, Central Circle-2(3) Mumbai, 8Th Floor Old Cgo Ltd., (Formerly Known As Sls Annexure Building, Tubes Pvt. Ltd., M.K.Road, Marine Lines 43, 1St Carpenter Street, Mumbai – 400 020 C.P.Tank, Mumbai-400004 Maharashtra India Pan/Gir No. Aalcs1837M (Appellant) .. (Respondent) Joint Commissioner Of Vs. M/S. Hellios Tubealloys Pvt. Ltd., Income Tax (Osd) (Formerly Known As Sls Tubes Central Circle-2(3), Room Pvt. Ltd., No.803, 8Th Floor, 43, 1St Carpenter Street, Old Cgo Annex Building C.P.Tank, Mumbai-400004 M.K.Road, Maharashtra Mumbai – 400 020 India Pan/Gir No. Aalcs1837M (Appellant) .. (Respondent) M/S. Sls Stainless Pvt Ltd., Vs. Dcit, Central Circle-2(3) 43, 1St Carpenter Street Mumbai, 8Th Floor Old Cgo C.P.Tank, Annexure Building, M.K.Road, Mumbai – 400 004 Marine Lines Maharashtra Mumbai – 400 020 Pan/Gir No. Aadcs1273P (Appellant) .. (Respondent) M/S. Sls Tubes Pvt. Ltd. & M/S. S.L.S. Stainless P. Ltd., Joint Commissioner Of Vs. M/S. Sls Stainless Pvt Ltd., 43, 1St Carpenter Street, Income Tax (Osd) Central Circle-2(3), Room C.P.Tank, Mumbai-400004 No.803, 8Th Floor, Maharashtra Old Cgo Annex Building India M.K.Road, Mumbai – 400 020 Pan/Gir No. Aadcs1273P (Appellant) .. (Respondent)

Section 133(6)Section 133ASection 143(3)Section 69C

pressed. 3. The only ground to be decided in these appeals is with regard to the issue of addition made on account of bogus purchases u/s.69C of the Act. 4. With the consent of both the parties, the appeals in the case of SLS Stainless Pvt. Ltd., in ITA No.1304/Mum/2018 ... after considering the submissions of the assessee and the materials available on record restricted the addition to 25% of the alleged bogus purchases which worked out to Rs.3,04,47,694/-. 5.2. Aggrieved, both the assessee as well as revenue are in appeal before us. 6. At the outset

ITO 21(1)(4), Mumbai vs. M/S Hide in, Mumbai

In the result, appeal filed by the revenue stands dismissed

ITA 3530/MUM/2019[2011-12]Status: DisposedITAT Mumbai21 Oct 2020AY 2011-12

revenue wherein the revenue is aggrieved that Learned Commissioner of Income Tax (Appeals) [in short learned CIT(A)] has reduced the addition for bogus purchase by Rs. 7,39,938/- done at the rate of 25% by the Assessing Officer by sustaining only 12.5%. 2. The assessee in this case ... information from sales tax department that assessee has made Rs. 17,37,660/- purchases from bogus dealers. The AO made 25% addition of the bogus purchase resulting in disallowance of Rs. 957,146/-. 3. Upon assessee's appeal learned CIT-A has noted that the sale has not been doubted

Shri Rajiv Bothra, Jaipur vs. Income Tax Officer, Ward-5-2, Ncrb, Jaipur

In the result, appeal of the assessee is dismissed

ITA 557/JPR/2019[2013-14]Status: DisposedITAT Jaipur20 Oct 2020AY 2013-14

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 557/Jp/2019 Fu/Kzkj.K O"Kz@Assessment Year :2013-14 Rajiv Bothra, Cuke I.T.O., Vs. B-252, Janta Colony, Ward 5(2), Jaipur. Ncrb, Jaipur. Lfkk;H Ys[Kk La-@Thvkbzvkj La-@Pan/Gir No.: Aazpr 2080 A Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Written Submissions Jktlo Dh Vksj Ls@ Revenue By : Ms. Chanchal Meena (Addl.Cit) Lquokbz Dh Rkjh[K@ Date Of Hearing : 28/09/2020 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 21/10/2020 Vkns'K@ Order Per: Sandeep Gosain, J.M. The Present Appeal Has Been Filed By The Assessee Against The Order Of The Ld. Cit(A)-2, Jaipur Dated 19/03/2019 For The A.Y. 2013-14, Wherein The Assessee Has Raised Following Grounds Of Appeal: “1. That The Ld. Cit(A) Has Erred At Law As Well As On Facts In Invoking Provisions Of Section 145 For Confirming The Addition Made When The Assessing Officer Had Made The Trading Additions Without Invoking Provisions Of Section 145. 2. That The Ld. A.O. Had Erred At Law As Well As On Facts In Arbitrarily Treating Purchases Made From Maximus Gems, Surya Diam & Navkar India Of Rs. 71,32,000/-, Rs. 10,09,250/- & Rs. 9,01,600/- Respectively In Total Of Rs. 90,42,850/- Are Non-Verifiable Purchases & The Ld. Cit(A) Also Erred In Confirming That The Purchases Made From These Parties Are Non-Verifiable.

For Appellant: Written SubmissionsFor Respondent: Ms. Chanchal Meena (Addl.CIT)
Section 143(3)Section 145Section 145(3)

Income Tax Act, 1961 (in short, the Act) and assessed the total income of Rs. 33,22,772/- by making addition on account of bogus purchases. 4. Being aggrieved by the order of the A.O., the assessee carried the matter before the ld. CIT(A), who after considering the case ... order and the submissions of the appellant. It is seen that the trading addition was made by the Assessing Officer on the basis of bogus purchases. Before me also, ld. Authorized Representative has failed to justify purchases alleged as bogus. In the view of the above facts, books of accounts

Surajmal Mehta, Mumbai vs. ITO - 19(3)(4), Mumbai

In the result, appeals filed by the assessee for assessment years 2010-11

ITA 3691/MUM/2019[2010-11]Status: DisposedITAT Mumbai20 Oct 2020AY 2010-11

Bench: Shri Shamim Yahya (Am) & Shri Ram Lal Negi (Jm) Assessment Year: 2010-11 & Assessment Year: 2011-12 Surajmal Mehta, The Income Tax Officer-19(3)(4), 24-I, 2Nd Carpenter Street, Matru Mandir, 2Nd Floor, Nd Road, Tardeo Road, Grant Road, Mumbai - 400004 Vs. Mumbai - 400007 Pan: Aadpm9634P (Appellant) (Respondent)

For Appellant: Assessee’s withdrawal letter datedFor Respondent: Shri Jitendra Kumar (DR)
Section 143Section 4

inter alia on the ground that the Ld. CIT (A) has erred in upholding the addition of 12.5% of the total amount of bogus purchases made by the AO. Assessment Years: 2010-11 & 2011-12 3. These appeals were fixed for hearing on 19.10.2020. None appeared on behalf

Amar Diamond Tools, Mumbai vs. ITO WD 1(1), Thane

In the result, all the appeals are allowed

ITA 6547/MUM/2018[2010-11]Status: DisposedITAT Mumbai19 Oct 2020AY 2010-11

Bench: Shri Shamim Yahya (Am)

Section 133(6)

Assessment as aforesaid. 2. In all the appeals the assessee is aggrieved that learned CIT(A) erred in sustaining 12.5% disallowance out of bogus purchases. These appeals were earlier disposed by the Tribunal ex-parte vide order dated 5.12.2019. Later they were recalled vide order in Miscellaneous Application order dated ... that in this case the sales have not been doubted. It is settled law that when sales are not doubted, hundred percent disallowance for bogus purchase cannot be done. The rationale being no sales is possible without actual purchases. This proposition is supported from honourable jurisdictional High Court decision

Primex Metal, Mumbai vs. ITO, 19(2)(5), Mumbai

In the result, these appeals are partly allowed

ITA 1478/MUM/2019[2009-10]Status: DisposedITAT Mumbai19 Oct 2020AY 2009-10

assessee is aggrieved that the Learned Commissioner of Income Tax (Appeals) [in short learned CIT(A)] has erred in sustaining the addition for bogus purchase of Rs. 4,16,009/- for A.Y. 2010-11 and Rs. 11,08,288/- for A.Y. 2009-10 done by Assessing Officer ... reopened upon information from sales tax department that assessee has made purchases from bogus dealers, the Assessing Officer made 12.5% addition of the bogus purchase. Though the Assessing Officer observed that assessee has not shown corresponding sales out of bogus purchases, he chose to disallow only 12.5%. The Assessing Officer

The DCIT(OSD), Circle-9, Ahmedabad vs. M/S. Shukan Builders, Ahmedabad

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

ITA 1697/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad16 Oct 2020AY 2010-11
For Appellant: Shri S. N. Soparkar with SmtFor Respondent: Shri Virendra Ojha CIT DR with Shri Dileep Kumar, Sr. DR
Section 143(3)

assessee is that the Learned CIT(A) erred in 2. confirming the addition made by the AO amounting to Rs.62,51,247/- as bogus purchases. 3. The facts in brief are that the assessee in the present case is a partnership firm and engaged in the business of building construction ... registration of these parties the VAT Department were also cancelled. Thus, based on these facts, it can be inferred that purchases represents the bogus purchases. But, before we arrive at any conclusion, the fact that needs to be considered is that the assessee has shown such purchases in its stock

Shukan Builders, Ahmedabad vs. The Dy.CIT(OSD), Circle-9, Ahmedabad

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

ITA 1518/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad16 Oct 2020AY 2010-11
For Appellant: Shri S. N. Soparkar with SmtFor Respondent: Shri Virendra Ojha CIT DR with Shri Dileep Kumar, Sr. DR
Section 143(3)

assessee is that the Learned CIT(A) erred in 2. confirming the addition made by the AO amounting to Rs.62,51,247/- as bogus purchases. 3. The facts in brief are that the assessee in the present case is a partnership firm and engaged in the business of building construction ... registration of these parties the VAT Department were also cancelled. Thus, based on these facts, it can be inferred that purchases represents the bogus purchases. But, before we arrive at any conclusion, the fact that needs to be considered is that the assessee has shown such purchases in its stock

ITO, Ward 3 (5), Kalyan vs. Jatin S. Gandhi, Mumbai

Accordingly, the grounds raised by the revenue stands dismissed

ITA 2019/MUM/2019[2009-10]Status: DisposedITAT Mumbai15 Oct 2020AY 2009-10

Bench: Shri C. N. Prasad, Jm & Shri S. Rifaur Rahman, Am आयकरअपीलसं./ I.T.A. No. 2019 & 2020/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2009-10 & 2010-11)

For Respondent: None
Section 271Section 271(1)(c)

brief facts of the case are that AO levied penalty u/s 271(1)(c) of the Act on account of bogus purchases made by the 3 I.T.A. No 2019 & 2020/Mum/2019 Shri Jatin S. Gandhi assessee. On appeal before Ld. CIT(A), Ld. CIT(A) has deleted the penalty by considering ... income or furnished 4 I.T.A. No 2019 & 2020/Mum/2019 Shri Jatin S. Gandhi inaccurate particulars of such income. However, the estimation of disallowance on bogus purchases by the AO cannot be termed as either concealment or furnishing of inaccurate particulars of income. 9. We find support from the series of decisions

Shripal Rashmikant Daftary, Mumbai vs. ITO- 29(3)(4), Mumbai

In the result appeal filed by the assessee stands allowed

ITA 393/MUM/2019[2010-11]Status: DisposedITAT Mumbai15 Oct 2020AY 2010-11
Section 271Section 271(1)(c)

penalty by observing as under :- “During the assessment proceedings based on the information received from Sales Tax Department and DGIT(Inv), Mumbai, about bogus purchase bills being obtained from bogus hawala bills providers, the AO after having considered the assessee's submission that all the purchases made through proper channel ... above submission made by the AR of the appellant, the AO added to the extent of 12.5% being gross profit on the alleged bogus purchases. The appellant in his submissions stated that in order to buy peace and avoid further litigation, accepted the additions made to the extent

ITO 22 (1)(4), Mumbai vs. Jignesh H. Ruparelia, Mumbai

In the result these appeals filed by the revenue stand dismissed

ITA 2278/MUM/2019[2010-11]Status: DisposedITAT Mumbai14 Oct 2020AY 2010-11

Bench: The Itat. None Appeared On Behalf Of The Assessee During The Course Of Virtual Hearing. I Find

revenue wherein the revenue is aggrieved that Learned Commissioner of Income Tax (Appeals) [in short learned CIT(A)] has reduced the addition for bogus purchase done @ 35% for A.Y. 2010-11 & 25% for A.Y. 2011-12 by Assessing Officer by sustaining only 12.5%. 2. The assessee is a proprietor ... from bogus dealers. The Assessing Officer made 35% addition of the bogus purchase amounting to Rs. 89,970/- for A.Y. 2011-12 and @ 25% for Rs. 4,25,754/- for A.Y. 2010-11. 3. Against above order revenue is in appeals before the ITAT. None appeared on behalf

ITO, Ward- 22(2)(1), Mumbai vs. Kumar Hasmukh Ruparelia, Mumbai

In the result this appeal filed by the revenue stands dismissed

ITA 2256/MUM/2019[2010-11]Status: DisposedITAT Mumbai14 Oct 2020AY 2010-11

revenue wherein the revenue is aggrieved that the Learned Commissioner of Income Tax (Appeals) [in short learned CIT(A)] has reduced the addition for bogus purchase of Rs. 5,70,985/- done @ 25% by Assessing Officer by sustaining only 12.5%. 2. The assessee in this case is engaged into ... from sales tax department that assessee has made Rs. 22,83,941/- purchases from bogus dealers. The Assessing Officer made 25% addition of the bogus purchase for Rs. 5,70,985/-. 3. Upon assessee's appeal learned CIT-A has noted that the sales has not been doubted. Accordingly placing

ITO 26 (2)(3), Mumbai vs. Nischal Chandrashekhar Shetty, Mumbai

In the result this appeal filed by the revenue stands dismissed

ITA 1875/MUM/2019[2010-11]Status: DisposedITAT Mumbai14 Oct 2020AY 2010-11

revenue wherein the revenue is aggrieved that Learned Commissioner of Income Tax (Appeals) [in short learned CIT(A)] has reduced the addition for bogus purchase of Rs. 8,39,328/- done @ 100% by Assessing Officer by sustaining only 15%. 2. The assessee in this case is engaged into the business ... from sales tax department that assessee has made Rs. 8,39,328/- purchases from bogus dealers. The Assessing Officer made 100% addition of the bogus purchase. 3. Upon assessee's appeal learned CIT-A has noted that the sale has not been doubted. Accordingly placing reliance upon several case laws

Pratiksha J. Kudtarkar, Mumbai vs. ITO - 26 (2)(4), Mumbai

In the result, appeals of the assessee for Assessment Years 2009-10 and 2010-11 are allowed

ITA 2674/MUM/2019[2010-11]Status: DisposedITAT Mumbai14 Oct 2020AY 2010-11

Bench: Shri Vikas Awasthy & Shri Rajesh Kumar

For Appellant: Ms. Neha SharmaFor Respondent: Shri Uodal Raj Singh
Section 271(1)(c)

pipe bending machines used in automobile industry. During the assessment proceedings for the impugned assessment years, the addition was made on account of bogus purchases by estimating gross profit at 25% in Assessment Year 2009-10 and 12.5% in Assessment Year 2010-11. The Assessing Officer initiated penalty proceedings under ... Section 271(1)(c) of the Act in respect of addition made on account of bogus purchases and levied penalty of Rs.70,424/- in Assessment Year 2009-10 and Rs.1,25,874/- in Assessment Year 2010-11. The assessee filed appeals before the CIT(A) assailing levy of penalty

Pratiksha J. Kudtarkar, Mumbai vs. ITO - 26 (2)(4), Mumbai

In the result, appeals of the assessee for Assessment Years 2009-10 and 2010-11 are allowed

ITA 2673/MUM/2019[2009-10]Status: DisposedITAT Mumbai14 Oct 2020AY 2009-10

Bench: Shri Vikas Awasthy & Shri Rajesh Kumar

For Appellant: Ms. Neha SharmaFor Respondent: Shri Uodal Raj Singh
Section 271(1)(c)

pipe bending machines used in automobile industry. During the assessment proceedings for the impugned assessment years, the addition was made on account of bogus purchases by estimating gross profit at 25% in Assessment Year 2009-10 and 12.5% in Assessment Year 2010-11. The Assessing Officer initiated penalty proceedings under ... Section 271(1)(c) of the Act in respect of addition made on account of bogus purchases and levied penalty of Rs.70,424/- in Assessment Year 2009-10 and Rs.1,25,874/- in Assessment Year 2010-11. The assessee filed appeals before the CIT(A) assailing levy of penalty

ITO 27 (1)(5), Mumbai vs. M/S Gluck (India) Manufacturing Company, Mumbai

In the result this appeal filed by the revenue stands dismissed

ITA 1838/MUM/2019[2009-10]Status: DisposedITAT Mumbai14 Oct 2020AY 2009-10

Bench: The Itat. None Appeared On Behalf Of The Assessee In The Course Of Virtual Hearing. I Find That In This 2 M/S. Gluck (India) Manufacturing Company

revenue wherein the revenue is aggrieved that Learned Commissioner of Income Tax (Appeals) [in short learned CIT(A)] has reduced the addition for bogus purchase of Rs. 3,76,530/- done @ 100% by Assessing Officer by sustaining only 12.5%. 2. The assessee in this case is engaged into business ... from sales tax department that assessee has made Rs. 3,76,530/- purchases from bogus dealers. The Assessing Officer made 100% addition of the bogus purchase. 3. Upon assessee's appeal learned CIT-A has noted that the sale has not been doubted. Accordingly placing reliance upon several case laws

ITO 15 (1)(4), Mumbai vs. M/S Gayatri Rubchem Pvt. Ltd, Mumbai

In the result this appeal filed by the revenue stands dismissed

ITA 1788/MUM/2019[2010-11]Status: DisposedITAT Mumbai14 Oct 2020AY 2010-11

Bench: The Itat. I Have Heard Learned Departmental Representative & Perused The Record. I Find That In 2 M/S. Gayatri Rubchem Private Limited

revenue wherein the revenue is aggrieved that Learned Commissioner of Income Tax (Appeals) [in short learned CIT(A)] has reduced the addition for bogus purchase of Rs. 16,84,188/- done @ 100% by Assessing Officer by sustaining only 12.5%. 2. The assessee in this case is engaged into business ... from sales tax department that assessee has made Rs. 16,84,188/- purchases from bogus dealers. The Assessing Officer made 100% addition of the bogus purchase. 3. Upon assessee's appeal learned CIT-A has noted that the sale has not been doubted. Accordingly placing reliance upon several case laws

DCIT 15(2)(2), Mumbai vs. Indocen Electronic System P.Ltd, Navi Mumbai

In the result, appeal of the Revenue is dismissed

ITA 6134/MUM/2018[2010-11]Status: DisposedITAT Mumbai13 Oct 2020AY 2010-11

Bench: Shri Vikas Awasthy & Shri Rajesh Kumar: A.Y : 2010-11

For Appellant: Shri Uodal Raj SinghFor Respondent: Shri Ashok Puri
Section 143(3)Section 147

basis of information received from Maharashtra Sales Tax Department. As per the information received, the assessee had obtained bogus purchase bills to the tune of Rs.37,99,718/- from the following hawala dealers :- i) R.K. Enterprise - Rs.18,53,696 ii) Rumggt Enterprises - Rs. 6,50,104 iii) Grifton India Riddhi ... Enterprises - Rs.12,95,918 Total Rs.37,99,718 The Assessing Officer made addition of the entire alleged bogus purchase. Aggrieved against the assessment order dated 20.12.2017 passed under Section 143(3) r.w.s. 147 of the Act, the assessee filed appeal before the CIT(A). The CIT(A), following

ITO 27 (1)(4), Mumbai vs. M/S Inka Engineers, Mumbai

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

ITA 1873/MUM/2019[2009-10]Status: DisposedITAT Mumbai12 Oct 2020AY 2009-10

case and in law, the Ld. CIT(A) erred in deleting the addition of Rs.79,887/- made by the Assessing Officer on account of bogus purchases, without appreciating the fact that the assessee had failed to produce bills, vouchers and other documentary evidences in support of its claim and without ... erred in estimating the profit from Hawala purchases by disallowing only Rs.11,413/-, being 12.5% of the bogus purchases as even the basic onus of producing delivery challans, transportation details etc. were not fulfilled by the assessee. 3) The appellant prays that the order