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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

Anandvalli Nambiraj Mudaliar, Mumbai vs. ITO, Ward - 2 (1), Kalyan

In the result, appeal of the assessee is partly allowed

ITA 7164/MUM/2018[2009-10]Status: DisposedITAT Mumbai25 Feb 2020AY 2009-10

Bench: Shri R.C. Sharma (A.M.) & Shri Pawan Singh (Jm) - Ay 2009-10 - Ay 2010-11 - Ay 2011-12 Anandvalli Nambiraj Vs Ito, Wd.2(1), Kalyan 2Nd Mudaliar, Floor, Mohan Plaza, Wayle Nagar, Khadakpada, Kalyan (W) – 421 301 Pan : Agipm4254G Appellant Respondednt

Section 133(6)Section 143(1)Section 147Section 148Section 69C

respectively. In all appeals, the assessee has raised identical / common grounds of appeals except for variation in figures of disallowance u/s 69C / bogus purchases. Facts in all appeals are also common, therefore, with the consent of parties, all appeals were clubbed, heard and are decided by consolidated order. For appreciation ... 7166/Mum/2018 4. On appeal before CIT(A), the assessee challenged the reopening of the assessment as well as the addition made on account of bogus purchases. The Ld.CIT(A) while passing the appellate order noted that assessee was given numerous opportunities. The assessee neither replied nor provided any details; only

DCIT Circle-3, Thane vs. M/S Shree Jain Traders, Thane

In the result, the appeal is dismissed

ITA 309/MUM/2019[2010-11]Status: DisposedITAT Mumbai24 Feb 2020AY 2010-11

Bench: Shri C.N. Prasad () & Shri N.K. Pradhan () Assessment Year: 2010-11

For Appellant: Mr. Subodh Ratnaparkhi, ARFor Respondent: Mr. V. Vinod Kumar, DR
Section 143(3)Section 271(1)(c)

declaring total income of Rs.17,99,382/-. On receipt of information from the Sales Tax Department, Government of Maharashtra that the assessee had obtained bogus purchase bills of Rs.3,35,814/- from Payal Enterprises during the year under consideration, the AO made an addition of the above amount while framing ... deleted the penalty levied by the AO on the reason that (i) in quantum appeal, the then CIT(A) had adjudicated that 12.5% of bogus purchases of Rs.3,35,814/- is to be added to the income of the assessee; (ii) the addition to income has been sustained on estimation

ITO 27(3)(3), Mumbai vs. M/S.Sonal Plastics, Mumbai

In the result, the appeal is dismissed

ITA 5194/MUM/2018[2009-10]Status: DisposedITAT Mumbai24 Feb 2020AY 2009-10

Bench: Shri C.N. Prasad () & Shri N.K. Pradhan () Assessment Year: 2009-10

For Appellant: NoneFor Respondent: Mr. V. Vinod Kumar, DR
Section 133(6)Section 143(3)Section 271(1)(c)

completed by the Assessing Officer (AO) on 27.03.2015 by making two additions i.e. (i) disallowance of Rs.2,69,756/- with regard to bogus purchases and (ii) disallowance of Rs.35,311/- towards expenses. Herein, the dispute is with regard to disallowance of Rs.2,69,756/- made by the AO. The background ... that that the AO received information from the Sales Tax Department, Government of Maharashtra that the assessee had obtained bogus purchases bills of Rs.21,58,052/- from Shree Yamuna Impex. In the assessment order, the AO estimated the profit @ 12.5% on such disputed purchases of Rs.21,58,052/- which comes

Income Tax Officer Ward-30(1)(4), Mumbai vs. M/S.G.K.Construction, Mumbai

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

ITA 7031/MUM/2017[2010-11]Status: DisposedITAT Mumbai24 Feb 2020AY 2010-11

Bench: Shri C.N. Prasad () & Shri N.K. Pradhan () Assessment Year: 2010-11

For Appellant: NoneFor Respondent: Mr. V. Vinod Kumar, DR
Section 133(6)Section 142(1)Section 143(3)

case and in law the Ld. CIT(A) erred in directing the Assessing Officer to delete the addition made on account of bogus purchase and directing that only 25% of bogus purchase of Rs.9,09,704/- may be taxed and balance of bogus purchase of Rs.27,29,110/- is deleted ... Tribunal in the case of Vijay Protein Ltd. v. CIT (2015) 58 taxmann.com 44 (Guj) estimated the profit @ 25% on such alleged bogus purchases of Rs.36,38,814/- (Rs.21,18,385/- + Rs.15,20,429/-) which comes to Rs.9,90,704/-. Thus he deleted the balance addition of Rs.27

Income-Tax Officer, Ward - 5(2), Pune vs. Pradeep Laxmanrao Dhumal, Pune

In the result, the appeal of Revenue is dismissed

ITA 2470/PUN/2017[2010-11]Status: DisposedITAT Pune21 Feb 2020AY 2010-11

Bench: Shri George Mathan, Jm & Shri Anil Chaturvedi, Am

For Appellant: Shri Pramod ShingteFor Respondent: Shri S.P. Walimbe

circumstances of the case the Ld CIT(A) has erred in restricting the addition made by the Assessing Officer on account of bogus purchases to Rs6,62,408/( i.em12.5% of the Hawala purchases of Rs 52,99,262/-) instead of upholding the entire addition of Rs 52,99,262/- contrary

Naresh Kumar Singhal & Sons, Faridabad vs. ITO, Ward-2(1), Faridabad

In the result, the appeal of the assessee is partly allowed

ITA 5586/DEL/2018[2008-09]Status: DisposedITAT Delhi21 Feb 2020AY 2008-09

Bench: Ms. Sushma Chowla

For Appellant: Sh. Suresh Kumar Gupta, CAFor Respondent: Sh. Pradeep Singh Gautam, Sr.DR
Section 144Section 147

assessment proceedings would become academic. 6. Briefly in the facts of the case the Assessing Officer had received certain information with regard to bogus purchases made by the assessee during the year through M/s. Maa Durga Trading Company. The assessee failed to appear before the Assessing Officer and assessment ... perusal of record and after hearing both the authorized representatives, the first issue on merits is the rate to be applied on the alleged bogus purchases. It is an established principle that even where the purchases are bogus, the entire amount of purchase cannot be added as income

Shri. Naresh C Mistry, Thane vs. ITO-3(1), Thane

In the result, appeal of assessee is partly allowed in the manner aforesaid

ITA 98/MUM/2019[2009-10]Status: DisposedITAT Mumbai20 Feb 2020AY 2009-10

Bench: Shri Vikas Awasthy & Shri N.K.Pradhanshri Naresh C. Mistry, M/S. Neo Mech Engineers, Plot No.C-30, Road No.16, Wagle Indusrial Estate, Thane (West) 400 604 Pan: Aawpm 0822A ...... Appellant

For Appellant: Shri Nishit GandhiFor Respondent: Shri R. Bhoopathi

Assessing Officer reopened the assessment on the basis of information received from Sales Tax Department, Government of Maharashtra that the assessee has obtained bogus purchase 4 bills amounting to Rs.2,36,914/- from three hawala dealers, i.e. Laxmi Trading Co. – Rs.52,728/-, Bhoomi Enterprises – Rs.1,04,020 and Impex Traders ... granted part relief to the assessee by restricting disallowance to 10% on regular purchases and expenditure claimed and confirmed the entire amount of bogus purchases. 6. The ld. Authorized Representative for the assessee submitted that the assessee in appeal has raised seven grounds of appeal including the sub- grounds

ITO Ward 1(4), Thane vs. Shri. Ganesh Chandrakant Dere, Thane

In the result, appeal of the Revenue is dismissed

ITA 371/MUM/2019[2010-11]Status: DisposedITAT Mumbai20 Feb 2020AY 2010-11

Bench: Shri Vikas Awasthyincome Tax Officer , Ward 1(4) 6Th Floor, ‘B’Wing, Room No.11, Wagle Industrial Estate, Thane(W) 400 604 ...... Appellant

For Appellant: Shri R. BhoopatiFor Respondent: None
Section 143(3)Section 271(1)(c)

Officer in reassessment proceedings vide order dated 06/02/2015 passed under section 143(3) r.w.s. 147 of the Act by estimating GP @ 12.04% on alleged bogus purchases. The Assessing Officer vide order dated 21/08/2015 levied penalty u/s 271(1)(c) of the Act on the estimated addition of alleged bogus purchases ... penalty u/s. 271(1)(c) of the Act. In the instant case penalty u/s. 271(1)(c) has been levied on the disallowance of bogus purchases made on estimation. It is a well settled legal position that no penalty is leviable on additions based on estimations. Merely for the reason

Iti, Ward-1(2), Thane West vs. M/S M T Phad - Kherade Enterprises, Thane

In the result, appeal of the Revenue is dismissed

ITA 370/MUM/2019[2010-11]Status: DisposedITAT Mumbai20 Feb 2020AY 2010-11

Bench: Shri Vikas Awasthyincome Tax Officer , Ward 1(2) 6Th Floor, ‘B’Wing, Room No.24, Ashar It Park, Road No.16Z, Wagle Industrial Estate, Thane(W) 400 604 ...... Appellant

For Appellant: Shri R. BhoopathiFor Respondent: None
Section 143(3)Section 271(1)(c)

reassessment proceedings vide order dated 05/02/2015 passed under section 143(3) 2 r.w.s. 147 of the Act by estimating GP @ 20% on alleged bogus purchases. The Assessing Officer vide order dated 19/08/2015 levied penalty u/s 271(1)(c) of the Act on the estimated addition of alleged bogus purchases ... penalty u/s. 271(1)(c) of the Act. In the instant case penalty u/s. 271(1)(c) has been levied on the disallowance of bogus purchases made on estimation. It is a well settled legal position that no penalty is leviable on additions based on estimations. Merely for the reason

ITO - WD- 3 (5), Kalyan vs. Radheshyam Babulal Vyas, Dombivali

In the result, appeal of the Revenue is dismissed

ITA 366/MUM/2019[2009-10]Status: DisposedITAT Mumbai20 Feb 2020AY 2009-10

Bench: Shri Vikas Awasthyincome Tax Officer , Ward 3(5) 2Nd Floor, Rani Mansion. Murbad Road, Kalyan(W) 421 301 ...... Appellant

For Appellant: Shri R. BhoopatiFor Respondent: Shri Sanjay Praikh
Section 271(1)(c)

addition of Rs.3,26,134/- was made by the Assessing Officer in reassessment proceedings on account of alleged bogus purchases made by the assessee. The Assessing Officer vide order dated 16/02/2015 levied penalty u/s 271(1)(c) of the Act on the addition of alleged bogus purchases. 3. Shri ... penalty u/s. 271(1)(c) of the Act. In the instant case penalty u/s. 271(1)(c) has been levied on the disallowance of bogus purchases. The Assessing Officer has made addition of entire bogus purchases and the same has been accepted by the assessee. The Tribunal in various decisions

ACIT-26(2), Mumbai vs. Pukhraj T Purohit, Mumbai

In the result, appeals of the Revenue are dismissed

ITA 147/MUM/2019[2010-11]Status: DisposedITAT Mumbai20 Feb 2020AY 2010-11

Bench: Shri Vikas Awasthy & Shri N.K.Pradhan

For Appellant: Shri R. BhoopatiFor Respondent: Ms. Kinjal Bhuta
Section 143(3)

information received from the Sales Tax Department, Government of Maharashtra, the Assessing Officer reopened the assessment for the reasons that assessee has obtained bogus purchase bills aggregating to Rs.52,43,128/- from various hawala dealers. The Assessing Officer held that since the assessee had failed to produce the parties from ... whom the alleged goods were purchased and has also failed to show trail of goods the assessee has indulged in obtaining bogus purchase bills. The Assessing Officer estimated GP on alleged bogus purchases @ 25%. Thus, the Assessing Officer made addition of Rs.13,10,782/- on account of non-genuine purchases

ACIT, Circle-9(3)(1), Mumbai vs. Filteration Engineers India Pvt Ltd, Mumnbai

In the result, appeal of the revenue is dismissed

ITA 1436/MUM/2019[2011-12]Status: DisposedITAT Mumbai20 Feb 2020AY 2011-12

Bench: Shri Pawan Singh & Shri S. Rifaur Rahman

For Appellant: Miss Samatha Mullamudi (Sr. DR)For Respondent: None
Section 143(3)Section 254(1)Section 271(1)(c)

completed under section 143(3) r.w.s. 147 dated 17.03.2016. The Assessing Officer while passing the assessment order made addition/disallowance on account of bogus purchases. The Assessing Officer disallowed 12.5% of aggregate of alleged bogus purchases of Rs. 1,12,35,102/-. The Assessing Officer calculated the disallowance ... section 143(3) r.w.s. 147. The Assessing Officer made the disallowance on estimated basis. The Assessing Officer disallowed 12.5% of aggregate of total alleged bogus purchases. The 3 ITA No. 1436 Mum 2019-M/s Filteration Engineers India Pvt. Ltd. Assessing Officer levied the penalty on the disallowances made while passing

ITO 33 (3)(2), Mumbai vs. Taruna R Dalal, Mumbai

In the result, appeal of the revenue is dismissed

ITA 7218/MUM/2018[2011-12]Status: DisposedITAT Mumbai20 Feb 2020AY 2011-12

Bench: Shri Vikas Awasthy & Shri G.Manjunathaito-33(3)(2), R.No.612, 6Th Floor, C-12, Pratyakshkar Bhavan, Bkc, Mumbai – 400 051 ...... Appellant

For Appellant: Ms. R. KavithaFor Respondent: None

information received from the Sales Tax Department, Maharashtra, the Assessing Officer reopened the assessment for assessment year 2011-12. The assessee had obtained bogus purchase bills amounting to Rs.4,71,672/- from M/s. Arun Paper and Iron Traders, a declared hawala operator. In assessment proceedings, the assessee failed to produce ... delivery challan, lorry receipt, etc. to substantiate trail of goods. Further, the assessee failed to provide the whereabouts of the dealer from whom bogus purchase bills were procured. The Assessing Officer estimated GP @25% on the bogus purchases, thus, disallowance of Rs.1,17,918/- was made by the Assessing Officer

ITO 27(1)(3), Mumbai vs. Hemal Maganlal Shah, Mumbai

In the result, appeal by the Revenue is dismissed and cross objections by the assessee are partly allowed

ITA 7137/MUM/2018[2009-10]Status: DisposedITAT Mumbai20 Feb 2020AY 2009-10

Bench: Shri Vikas Awasthy & Shri G.Manjunathaito 27(1)(3), Room No.409, 4Th Floor, Tower No.6, Vashi Rly. Station Complex, Vashi, Navi Mumbai 400 703 ...... Appellant

For Appellant: Ms. R.KavithaFor Respondent: S/Shri Nemish Rajesh Shah & Rajesh G. Shah
Section 143(3)

assessee submitted that the assessee is a trader of building material. In the reassessment proceedings the Assessing Officer held that the assessee had made bogus purchases aggregating to Rs. Rs.35,81,045/- from various hawala dealers. The ld. Authorized Representative for the assessee submitted that during assessment proceedings the assessee ... assessee filed appeal before CIT(A). The CIT(A) after examining the facts estimated GP @ 12.5% of the alleged bogus purchases. The ld. Authorized Representative for the assessee submitted that the estimation made by the CIT(A) is on the higher side. The ld. Authorized Representative for the assessee prayed

JCIT (OSD) -Centtral Circle (4), Mumbai vs. Shri Kamlesh Manohar Kanungo (Prop. Trison Implex), Mumbai

ITA 3087/MUM/2016[2007-08]Status: DisposedITAT Mumbai20 Feb 2020AY 2007-08

Bench: Shri M. Balaganesh & Shri Ravish Soodita Nos. 3087 & 3088/Mum/2016 (Assessment Years:2007-08 & 2008-09) Jcit (Osd) – Central Circle 1(4) Shri Kamlesh Manohar Kanungo R. No. 902, 9Th Floor, Old Cgo Buld. (Prop. Trison Impex) M.K. Road, Church Gate, 2Nd Floor, Apsara Cinema Bldg. Vs. Mumbai – 400 020 Dr. D.B. Marg, Grant Road (E), Mumbai – 400007

For Appellant: Shri S.C. Tiwari, CIT D.RFor Respondent: Shri Rajkumar Singh, A.R
Section 143(3)

Tech Oil & Gas Services Pvt. Ltd. Survey proceedings were conducted at the premises of the assessee, which therein revealed that he had carried out bogus purchases from M/s Aakaash Ferromet Pvt. ltd., M/s Adhunik Steel Corporation and M/s Arihant Trading Company over different years. On a perusal of the records ... Rs.1,65,33,581/- and an addition of commission expenses of Rs.1,90,335/-. For A.Y. 2008-09 the disallowance on account of bogus purchases was Rs.1,60,43,273/- and the addition towards commission expenses was estimated at Rs.6,85,749/-. 3. Aggrieved, the assessee assailed the respective assessments

Maharashtra Engineering, Kolhapur vs. Pr. Commissioner of Income-Tax -1, Kolhapur

In the result, the appeal of the assessee is allowed

ITA 859/PUN/2018[2010-11]Status: DisposedITAT Pune19 Feb 2020AY 2010-11

Bench: Shri George Mathan & Shri Anil Chaturvedi

For Appellant: Shri Rajesh ShahFor Respondent: Shri Deepak Garg
Section 143(3)Section 147Section 148Section 263Section 68

Taxman.com 289 (Gujarat) to say that when the entire purchases were found to be bogus then confirming the disallowance of 5% of the bogus purchases goes against the principles of section 68 of the Act. It was the submission that since the assessee did not get adequate time

DCIT 5(2)(1), Mumbai vs. M/S Karp Impex Limited, Mumbai

ITA 899/MUM/2019[2010-11]Status: DisposedITAT Mumbai19 Feb 2020AY 2010-11

Bench: Shri Vikas Awasthy, Jm & Shri S. Rifaur Rahman, Am आयकरअपीलसं./ I.T.A. No. 899/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2010-11)

For Appellant: Shri Drop Singh Meena, DR byFor Respondent: None
Section 143(3)Section 147Section 69C

Aggrieved with the above order, assessee preferred appeal before Ld. CIT(A) and Ld. CIT(A) sustained the addition of bogus purchases, but reduced the disallowance @ 3%. Subsequently, AO initiated penalty proceedings and imposed 3 I.T.A. No 899/Mum/2019 M/s Karp Impex Ltd. 5. Aggrieved with the above order, revenue ... circumstances of the case and in law, the Ld. CIT(A) erred in deleting the penalty levied on disallowance made on account of bogus purchases which was done on the basis of information received from investigation wing." 2. "Whether on the facts and circumstances of the case

ACIT 27(2), Mumbai vs. Kalpesh P. Pujara, Mumbai

ITA 7111/MUM/2018[2009-10]Status: DisposedITAT Mumbai19 Feb 2020AY 2009-10

Bench: Shri Vikas Awasthy, Jm & Shri S. Rifaur Rahman, Am आयकरअपीलसं./ I.T.A. No. 7111/Mum/2018 (निर्धारणवर्ा / Assessment Year: 2009-10)

For Appellant: Shri Drop Singh Meena, DR byFor Respondent: None
Section 143(3)Section 147Section 69C

subsequently assessment was completed u/s 143(3) r.w.s 147 of the Act by the AO. AO made 100% addition of the bogus purchases u/s 69C of the Act. 4. Aggrieved with the above order, assessee preferred appeal before Ld. CIT(A) and based on the submission of assessee ... erred in deleting the addition of Rs 6,60,569/- made by the Assessing Officer on account of bogus purchases, without appreciating the fact that the assessee has failed to produce bills, vouchers and other documentary evidences in support of its claim and without considering the latest Apex Court decision

ITO 27 (1)(5), Mumbai vs. Jignesh R. Kapasi, Mumbai

In the result, appeal of the revenue is dismissed

ITA 6430/MUM/2018[2009-10]Status: DisposedITAT Mumbai19 Feb 2020AY 2009-10

Bench: Shri Pawan Singh & Shri S. Rifaur Rahmanito 27(1)(5), Shri Jignesh R. Kapasi, Room No. 410, 4Th Floor, 1, Hansa Apartment, 126/127, Vs. Tower No.6, Vashi Railway Garodia Nagar, Ghatkopar Station Complex, Vashi, (E), Mumbai-400077. Navi Mumbai-400703. Pan: Aabpk2503R Appellant Respondent Appellant By : Mrs. Samatha Mullamudi (Dr) Respondent By : Shri M.R. Tanna (Ar) Date Of Hearing : 19.02.2020 Date Of Pronouncement : 19.02.2020 Order Under Section 254(1)Of Income Tax Act Per Pawan Singh; 1. This Appeal By Revenue Under Section 253 Of Income-Tax Act (‘Act’) Is Directed Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-

For Appellant: Mrs. Samatha Mullamudi (DR)For Respondent: Shri M.R. Tanna (AR)
Section 133(6)Section 139(1)Section 143(1)Section 143(2)Section 147Section 148Section 253Section 254(1)

circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition of Rs. 1,84,367/- on account of bogus purchases without appreciating that the onus was on the assessee to establish the genuineness of such purchases by providing documentary evidence before the Assessing Officer ... took his view that it would be just fair and proper to make addition of profit element embedded in such bogus purchase. The assessing officer accepted the confirmation filed by Dharmi Enterprises and allowed the purchases of Rs. 39,37,066/-. The assessing officer disallowed 12.5% of the aggregate

Mehta Emporium Jewellers, Mumbai vs. Joint Commissioner of Income Tax Range -30(2), Mumbai

The appeal stands partly allowed in terms of our above order

ITA 4810/MUM/2018[2013-14]Status: DisposedITAT Mumbai19 Feb 2020AY 2013-14

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Ms. Radha Halbe-Ld.ARFor Respondent: Ms. Jyoti Lakshmi Nayak-Ld. DR
Section 132Section 133(6)Section 250

circumstances of case and in law, the learned CIT(A)-41, Mumbai erred in confirming disallowance of Rs.16,20,078/- being 12.5% of alleged bogus purchases of Rs.1,29,60,626/- from M/s Rajan Gems, made by Assessing Officer merely on the basis of statement of third party Shri Dharmendra ... learned CIT(A)-41, Mumbai erred in confirming addition of Rs.8,38,590/- out of Rs.24,61,850/- being 12.5% of alleged bogus purchases of Rs.1,96,94,796/- made from M/s Rishi Exports and M/s, Ridhi International. 3. In the facts and circumstances of case