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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

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

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

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

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

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

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

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

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

Ashok Panchand Mehta HUF, Mumbai vs. ITO 22(1)(2), Mumbai

In the result, the appeals filed by the assessee are partly allowed

ITA 4861/MUM/2018[2010-11]Status: DisposedITAT Mumbai05 Nov 2019AY 2010-11

Bench: Shri Shamim Yahya & Shri Ram Lal Negi

For Appellant: Ms. Ruchi M. RathodFor Respondent: Shri Chaitanya Anjaria

appeals by the assessee wherein the assessee is aggrieved that the learned CIT(A) has erred in sustaining 12.5 percent disallowance on account of bogus purchases, vide common order dated 29.06.2018 pertaining to assessment years 2009-10 & 2010-11. 2. Brief facts of the case are that assessee in this ... chemicals and solvent. The assessment in this case was reopened upon receipt of information from the Sales Tax Department that assessee has made bogus purchases. The assessee submitted the purchase vouchers and the payments were made through banking channel. However the suppliers were not produced before the Assessing Officer. Sales

Ashok Panchand Mehta HUF, Mumbai vs. ITO 22(1)(2), Mumbai

In the result, the appeals filed by the assessee are partly allowed

ITA 4860/MUM/2018[2009-2010]Status: DisposedITAT Mumbai05 Nov 2019AY 2009-2010

Bench: Shri Shamim Yahya & Shri Ram Lal Negi

For Appellant: Ms. Ruchi M. RathodFor Respondent: Shri Chaitanya Anjaria

appeals by the assessee wherein the assessee is aggrieved that the learned CIT(A) has erred in sustaining 12.5 percent disallowance on account of bogus purchases, vide common order dated 29.06.2018 pertaining to assessment years 2009-10 & 2010-11. 2. Brief facts of the case are that assessee in this ... chemicals and solvent. The assessment in this case was reopened upon receipt of information from the Sales Tax Department that assessee has made bogus purchases. The assessee submitted the purchase vouchers and the payments were made through banking channel. However the suppliers were not produced before the Assessing Officer. Sales

Apratim Equipments, Mumbai vs. Income Tax Officer, Ward 3(1), Kalyan

In the result, the appeals filed by the assessee are partly allowed

ITA 4857/MUM/2018[2010-11]Status: DisposedITAT Mumbai05 Nov 2019AY 2010-11

Bench: Shri Shamim Yahya

For Appellant: Shri Madhav M. KhistiFor Respondent: Shri Chaitanya Anjaria

years 2009-10 & 2010-11. 2. The assessee is aggrieved that the learned CIT(A) has erred in sustaining 100% disallowance on account of bogus purchase. 3. Brief facts of the case are that the assessee in this case is engaged in the business of manufacturing of engineering goods ... assessments in these cases were reopened upon receipt of information from the Sales Tax Department that the assessee has made bogus purchases. The assessee submitted the purchase vouchers and the payments were made through banking channel. However, the suppliers were not produced before the Assessing Officer. Sales in this case

Apratim Equipments, Mumbai vs. Income Tax Officer, Ward 3(1), Kalyan

In the result, the appeals filed by the assessee are partly allowed

ITA 4856/MUM/2018[2009-10]Status: DisposedITAT Mumbai05 Nov 2019AY 2009-10

Bench: Shri Shamim Yahya

For Appellant: Shri Madhav M. KhistiFor Respondent: Shri Chaitanya Anjaria

years 2009-10 & 2010-11. 2. The assessee is aggrieved that the learned CIT(A) has erred in sustaining 100% disallowance on account of bogus purchase. 3. Brief facts of the case are that the assessee in this case is engaged in the business of manufacturing of engineering goods ... assessments in these cases were reopened upon receipt of information from the Sales Tax Department that the assessee has made bogus purchases. The assessee submitted the purchase vouchers and the payments were made through banking channel. However, the suppliers were not produced before the Assessing Officer. Sales in this case

Karan Ramchand Morani, Mumbai vs. Income Tax Officer Ward 22(2)(1), Mumbai

In the result, the appeals filed by the assessee are partly allowed

ITA 4830/MUM/2018[2007-08]Status: DisposedITAT Mumbai05 Nov 2019AY 2007-08

Bench: Shri Shamim Yahya

For Appellant: Shri Neelkhanth KhandelwalFor Respondent: Shri Chaitanya Anjaria

appeals by the assessee wherein the assessee is aggrieved that the learned CIT(A) has erred in sustaining 25% disallowance on account of bogus purchases, vide common order dated 31.05.2018 pertaining to assessment years 2007-08, 2009-10, 2011-12 & 2012013. 2. Brief facts of the case are that ... Assessment in this case was reopened upon receipt of information from Departmental Investigation Wing for investigation in Bhanwarlal Jain Group that assessee has made bogus purchases. The assessee submitted the purchase vouchers and payments were made through banking channel. The suppliers also responded to the notice of the Assessing Officer

Karan Ramchand Morani, Mumbai vs. Income Tax Officer Ward 22(2)(1), Mumbai

In the result, the appeals filed by the assessee are partly allowed

ITA 4829/MUM/2018[2011-12]Status: DisposedITAT Mumbai05 Nov 2019AY 2011-12

Bench: Shri Shamim Yahya

For Appellant: Shri Neelkhanth KhandelwalFor Respondent: Shri Chaitanya Anjaria

appeals by the assessee wherein the assessee is aggrieved that the learned CIT(A) has erred in sustaining 25% disallowance on account of bogus purchases, vide common order dated 31.05.2018 pertaining to assessment years 2007-08, 2009-10, 2011-12 & 2012013. 2. Brief facts of the case are that ... Assessment in this case was reopened upon receipt of information from Departmental Investigation Wing for investigation in Bhanwarlal Jain Group that assessee has made bogus purchases. The assessee submitted the purchase vouchers and payments were made through banking channel. The suppliers also responded to the notice of the Assessing Officer

Karan Ramchand Morani, Mumbai vs. Income Tax Officer Ward 22(2)(1), Mumbai

In the result, the appeals filed by the assessee are partly allowed

ITA 4828/MUM/2018[2009-10]Status: DisposedITAT Mumbai05 Nov 2019AY 2009-10

Bench: Shri Shamim Yahya

For Appellant: Shri Neelkhanth KhandelwalFor Respondent: Shri Chaitanya Anjaria

appeals by the assessee wherein the assessee is aggrieved that the learned CIT(A) has erred in sustaining 25% disallowance on account of bogus purchases, vide common order dated 31.05.2018 pertaining to assessment years 2007-08, 2009-10, 2011-12 & 2012013. 2. Brief facts of the case are that ... Assessment in this case was reopened upon receipt of information from Departmental Investigation Wing for investigation in Bhanwarlal Jain Group that assessee has made bogus purchases. The assessee submitted the purchase vouchers and payments were made through banking channel. The suppliers also responded to the notice of the Assessing Officer

Karan Ramchand Morani, Mumbai vs. Income Tax Officer Ward 22(2)(1), Mumbai

In the result, the appeals filed by the assessee are partly allowed

ITA 4827/MUM/2018[2012-13]Status: DisposedITAT Mumbai05 Nov 2019AY 2012-13

Bench: Shri Shamim Yahya

For Appellant: Shri Neelkhanth KhandelwalFor Respondent: Shri Chaitanya Anjaria

appeals by the assessee wherein the assessee is aggrieved that the learned CIT(A) has erred in sustaining 25% disallowance on account of bogus purchases, vide common order dated 31.05.2018 pertaining to assessment years 2007-08, 2009-10, 2011-12 & 2012013. 2. Brief facts of the case are that ... Assessment in this case was reopened upon receipt of information from Departmental Investigation Wing for investigation in Bhanwarlal Jain Group that assessee has made bogus purchases. The assessee submitted the purchase vouchers and payments were made through banking channel. The suppliers also responded to the notice of the Assessing Officer

Ramesh Sawantmal Bhansali, Mumbai vs. Income Tax Officer 19(3)(1), Mumbai

In the result assessee’s appeal is partly allowed

ITA 4690/MUM/2018[2010-11]Status: HeardITAT Mumbai05 Nov 2019AY 2010-11

For Appellant: Shri Rajkumar SinghFor Respondent: Shri Chaitanya Anjaria-DR

appeal by the assessee wherein the assessee is aggrieved that the learned CIT-A has erred in sustaining 12.5% disallowance on account of bogus purchases, vide order dated 13/04/2018 pertaining to assessment year 2010-11. 2 Ramesh Sawantmal Bhansali Assessment Year-2010-11 2. Brief facts of the case ... ferrous metal. 3. The assessment in this case was re-opened upon receipt of information from sales tax Department that assessee has made bogus purchases. The assessee submitted the purchase vouchers and the payments were made through banking channel. However, the suppliers were not produced before the Assessing Officer. Sales

M/S. Bipin Metal Products, Dhule vs. Assistant Commissioner of Income Tax, Dhule

In the result, all the appeals, except separately disposed off infra, are fully/partly allowed for statistical purposes

ITA 490/PUN/2017[2011-12]Status: DisposedITAT Pune04 Nov 2019AY 2011-12

For Appellant: Shri Sunil GanooFor Respondent: Shri Pankaj Garg

common order of CIT(A)-1, Nashik dated 11.01.2017. 2. In both the appeals, the issues are common and the same relates to the “bogus purchases and related additions”. 3. Before us, at the outset, without going to the other issues raised in the grounds, which are kept open ... dismissed. 11. Now we turn to the merits of the cases. The assail is to the making of addition(s) on the basis of bogus purchase bills received by the assessee(s) as accommodation entries from hawala dealers. It is seen that the issue of bogus purchases has recently come

M/S. Bipin Metal Products, Dhule vs. Assistant Commissioner of Income Tax, Dhule

In the result, all the appeals, except separately disposed off infra, are fully/partly allowed for statistical purposes

ITA 489/PUN/2017[2010-11]Status: DisposedITAT Pune04 Nov 2019AY 2010-11

For Appellant: Shri Sunil GanooFor Respondent: Shri Pankaj Garg

common order of CIT(A)-1, Nashik dated 11.01.2017. 2. In both the appeals, the issues are common and the same relates to the “bogus purchases and related additions”. 3. Before us, at the outset, without going to the other issues raised in the grounds, which are kept open ... dismissed. 11. Now we turn to the merits of the cases. The assail is to the making of addition(s) on the basis of bogus purchase bills received by the assessee(s) as accommodation entries from hawala dealers. It is seen that the issue of bogus purchases has recently come

Tushar M. Parekh Prop. Parekh Enterprises, Mumbai vs. Income Tax Officer-17(3)(4), Mumbai

In the result, this ground of appeal is allowed for statistical purpose

ITA 2452/MUM/2018[2010-11]Status: DisposedITAT Mumbai04 Nov 2019AY 2010-11

Bench: Shri Pawan Singh & Shri G. Manjunathatushar M Parekh Vs. Ito-17(3)(4) Prop. Parekh Enterprises Aaykar Bhawan M.K.Road 901, Nellai Chs, Swastik Park, Mumbai-400 020 S.T.Road, Chembur Mumbai-400 071

Section 139(1)Section 143(1)Section 143(2)Section 147Section 148Section 271(1)(b)

appellant prays that your honour hold that the books of accounts cannot be rejected by the C1T(A). C) Addition on account of alleged bogus purchases –Rs.6,97,23,136/- 6)The learned CIT(A) erred on facts and in law in confirming the addition made ... account of alleged bogus purchases amounting to Rs.6,97,23,136/- without appreciating that the appellant could not have sold the goods without purchasing the same. 7)The appellant prays that the addition of Rs, 6,97,23,136/-/- made by the AO on account of alleged bogus purchases

Assistant Commissioner of Income Tax 17(3), Mumbai vs. Vijay N. Mehta, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 5216/MUM/2017[2012-13]Status: DisposedITAT Mumbai04 Nov 2019AY 2012-13

Bench: Shri. Vikas Awasthy & Shri G. Manjunathaacit-17(3) Vs. Vijay N.Mehta Room No.137, 1St Floor Room No.13,338 Aaykar Bhawan,M.K.Marg N.N.Street Mumbai-400 020 Masjid Bunder(W) Mumbai-400 009 Pan/Gir No.Aadpm8512G (Appellant) .. (Respondent)

circumstances of the case and in law, the Learned CIT(A) has erred in holding that the AO to restrict the disallowance of bogus purchases to 4.27% of unverified purchases of Rs.2,22,79,213/-, without appreciating the facts that -' (i) In the assessment order, the assesses has not provided ... from DGIT, investigation, Mumbai, receles that Sales Tax Authorities of Government of Maharashtra had taken actions against number of Hawala dealers, who had issued bogus purchase bills to various parties in Mumbai. As per list of beneficiaries, the assessee is one of the beneficiary, who had taken accommodation bills

Shreenox Synthetics, Bhiwandi vs. Asst CIT Cir 1, Kalyan

In the result, appeal of the assessee is partly allowed

ITA 5788/MUM/2016[2009-10]Status: DisposedITAT Mumbai04 Nov 2019AY 2009-10

Bench: Shri R.C. Sharma & Shri Pawan Singhm/S Shreenox Synthetics Acit - 19(1)(3) Circle-1, 1St Floor, Sr.No. 9, 548, Aasbibi, Kalyan Road, Bhiwandi-421302. Vs. Mohan Plaza, Wayale Nagar, Pan: Abffs4088N Khadakpada, Kalyan (W) -421301 Appellant Respondent

For Appellant: Ms. Kiran Doifode (AR)For Respondent: Shri Manoj Kumar Singh (DR)

Section 139(1)Section 143(1)Section 143(3)Section 145(3)Section 147Section 148Section 254(1)

section 143(3) r.w.s. 147. ITA No. 5788 Mum 2016-M/s Shreenox Synthetics 4. Aggrieved by the additions of 100% disallowance of the alleged bogus purchases, in the assessment order, the assessee filed appeal before the ld. CIT(A). Before the ld. CIT(A), the assessee made elaborate submission ... were/are 7 ITA No. 5788 Mum 2016-M/s Shreenox Synthetics engaged in providing bogus bill without actual delivery of goods. The assessee has shown bogus purchases only to inflate the profit. The ld. DR for the revenue submits that the Assessing Officer has given sufficient relief

Hanwantraj A. Jain (HUF), Mumbai vs. ITO - WD- 19 (1)(5), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 5515/MUM/2018[2008-09]Status: DisposedITAT Mumbai01 Nov 2019AY 2008-09

Bench: Shri Shamim Yahya (Am) & Shri Pawan Singh (Jm)

Section 143Section 143(1)Section 143(2)Section 147Section 148Section 234ASection 271Section 3

assessee has raised identical grounds of appeal except variation of figure. Facts for both the Assessment Years are identical except variation of alleged bogus purchases and disallowances thereof @ 12.5% of such purchases. Therefore, both the appeals were clubbed, heard together and are decided by common order. For appreciation of facts ... disallowed and added to the total income of the assessee. 3. On appeal, the Ld.CIT(A) found the disallowance at 12.5% on the alleged bogus purchases to be reasonable. Therefore, he upheld the addition. Further aggrieved, the assessee filed this appeal. 4. We have heard the submissions of the learned

The Presscopper Industries, Mumbai vs. Income Tax Officer Ward 19(3)(5), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 5315/MUM/2018[2010-11]Status: DisposedITAT Mumbai01 Nov 2019AY 2010-11

Bench: Shri Shamim Yahya & Shri Pawan Singh

Section 133(6)Section 143(1)Section 143(2)Section 147Section 148

assessee has raised identical grounds of appeal except variation of figure. Facts for both the Assessment Years are identical except variation of alleged bogus purchases and disallowances thereof @ 12.5% of such purchases. Therefore, both the appeals were clubbed, heard together and are decided by common order. For appreciation of facts ... record. The ld. AR of the assessee submits that the assessee furnished complete details of purchases and the sales made against the alleged bogus purchases. The Assessing Officer has rejected the books of account without mentioning specific reasons. The Assessing Officer made the disallowance of 12.5% of the alleged bogus

Shri Suresh Amarlal Mehta, Mumbai vs. Income Tax Officer 19(3)(4), Mumbai

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

ITA 1672/MUM/2018[2010-11]Status: DisposedITAT Mumbai01 Nov 2019AY 2010-11

Bench: Shri Pawan Singh & Shri Rajesh Kumarshri Suresh Amarlal Mehta, Ito - 19(3)(4) M/S Nelco Steel India, 29, Matru Mandir, 2Nd Floor, Habib Building, 2Nd Vs. Mumbai. Panjrapole Lane, C.P. Tank, Mumbai-400004. Pan: Adbpm7463M Appellant Respondent

For Appellant: NoneFor Respondent: Shri Akhtar H. Ansari (Sr. AR)

Section 139(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 254(1)Section 271(1)(c)

erred in confirming the action of the A.O and approving the addition calculated by the A.O on alleged bogus purchases without appreciating the facts that the opinion of the A.O is based on merely presumptions and sub conjectures and ITA No. 1672 Mum 18- Shri Suresh Amarlal Mehta ... Shri Suresh Amarlal Mehta. view that it would be just fair and proper to make addition of profit element embedded in such bogus purchase; in the assessment order dated 09.02.2016 passed under section 143(3) r.w.s 147. 5. On appeal before the ld. CIT(A), the action of Assessing Officer

Gel Exim, Mumbai vs. ITO - 17 (1)(4), Mumbai

In the result, appeal filed by the assessee for assessment year 2010-

ITA 5747/MUM/2018[2010-11]Status: DisposedITAT Mumbai31 Oct 2019AY 2010-11

Bench: Shri S. Rifaur Rahman (Am) & Shri Ram Lal Negi (Jm) Assessment Year: 2010-11 Gel Exim, The Income Tax Officer- Shop No. 1, Ground Floor, 17(1)(4), Parda Cottage, 97 Aayakar Bhavan, M.K. Road, Narayan Dhuru Street, Vs. Mumbai - 400020 Mumbai - 400003 Pan: Aaifg0588K (Appellant) (Respondent) Assessee By : Pramita Rathi (Ar) Revenue By : Shri C.S. Sharma (Dr) Date Of Hearing: 26/09/2019 Date Of Pronouncement: 31/10/2019

For Appellant: Pramita Rathi (AR)For Respondent: Shri C.S. Sharma (DR)

Section 133(6)Section 143Section 143(1)Section 143(3)Section 147Section 148

sales tax department Maharashtra through DGIT (Investigation) to the effect that the assessee during the year relevant to the assessment year under consideration, obtained bogus purchase bills amounting to Rs. 1,70,62,476/- from M/s Bhavi Sales Agency Pvt. Ltd., whose Assessment Year: 2010-11 name was there ... rejected the claim of the assessee and treating the purchases as bogus made addition of 12.5% of the total amount of amount of bogus purchases and after making addition of the said amount determined the total income of the assessee at Rs.21,92,315/- In the first appeal

Sandeep Bhimrao Lad, Mumbai vs. DCIT Circle-3, Thane

ITA 1620/MUM/2018[2009-10]Status: DisposedITAT Mumbai31 Oct 2019AY 2009-10

Bench: Shri S. Rifaur Rahman, Am & Shri Ram Lal Negi, Jm आयकरअपीलसं./ I.T.A. No. 1620/Mum/2018 (निर्धारणवर्ा / Assessment Year: 2009-10)

For Appellant: Shri Subodh RatnaparkhiFor Respondent: Shri V. Vinod Kumar, DR

Section 133(6)Section 148Section 271Section 274

Sandeep Bhimrao Lad & Sunny Ashok Lad from the sales tax department, Maharashtra. The above information contained the details of certain person who had provided bogus purchase bills to the assessee for accommodation entries. The assessing officer noticed that one of the party was a provider of bogus purchase bills, accordingly ... officer issued show cause notice under section 133(6) of the Act and the notices were returned unserved. Accordingly assessing officer treated the above bogus purchases as income of the assessee. 4. Subsequently penalty proceedings were initiated by issue of notice under section

Assistant Commissioner of Income Tax 11(1)(2), Mumbai vs. Sanghvi Star Retail Private Limited, Mumbai

Accordingly, grounds raised in CO and case laws relied on by assessee are dismissed

ITA 5334/MUM/2017[2009-10]Status: DisposedITAT Mumbai31 Oct 2019AY 2009-10

Bench: Shri S. Rifaur Rahman, Am & Shri Ram Lal Negi, Jm आयकरअपीलसं./ I.T.A. No. 5334/Mum/2017 & Cross Objection No.– 01/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2009-10) M/S Sanghvi Star Retail Acit – 11(1)(2), Pvt. Ltd. Room No. 1, Ground बिधम/ Plot No. 75, C-14, Cross Floor, Aayakar Bhavan, Road, Marol Midc, Vs. M. K. Road, Anderi (East), Mumbai-400 020 Mumbai- 400 093 स्थायीलेखासं./जीआइआरसं./Pan No. Aalcs5646N (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant Shri V. Vinod Kumar, Dr : By प्रत्यथीकीओरसे/Respondentby : Shri Suchek Anchaliya, Ar सुनवाईकीतारीख/ : 09.10.2019 Date Of Hearing घोषणाकीतारीख / : 31.10.2019 Date Of Pronouncement आदेश / O R D E R Per S. Rifaur Rahman: The Present Appeal Has Been Filed By The Revenue Against The Order Of Ld. Commissioner Of Income Tax (Appeals) - 18 In Short Referred As ‘Ld. Cit(A)’, Mumbai, Dated 10.04.17 For Assessment Year (In Short Ay) 2009-10. 2

For Respondent: Shri Suchek Anchaliya, AR

Section 132Section 133Section 143

circumstances of the case and in law, the learned CIT(A) erred in deleting the addition of Rs.92,87,364/- on account of bogus purchases without appreciating the fact that the assessee has failed to produce any supporting evidence in the form of identify and genuineness of the 6 I.T.A ... latest decision of apex court in the case of N.K Protenins Ltd . Vs DCIT 2017(1) TMI 1090- Supreme Court in which 100% of bogus purchases are disallowed?". 4. "The appellant prays that the order of the CIT(A) on the above grounds be set aside and that