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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

Indrajit Properties Pvt Ltd (in Which Insco Steels Private Limited), Mumbai vs. Deputy Commissioner of Income Tax Central Circle -7(1), Mumbai

In the result, all the appeals raised by the assessee are allowed and all the appeals filed by the revenue are dismissed

ITA 2341/MUM/2025[2014-15]Status: DisposedITAT Mumbai22 Aug 2025AY 2014-15

Bench: SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153CSection 250

expenses by taking accommodation entries. In the present case, the allegation is that the appellant has booked back-to-back bogus sales and bogus purchases. Considering that both sales and purchases have been inflated, it doesn't seem that the transactions were carried out forsuppression of income. The issues ... After evaluating the records, the Ld. CIT(A) answered the first question by holding that the assessee has entered into circular transaction of bogus purchase and sales. Further, it was observed that the assessee had duly 9 reflected the profits earned in the books of accounts from such circular transactions

Indrajit Properties Pvt Ltd (in Which Insco Steels Pvt Ltd), Mumbai vs. Deputy Commissioner of Income Tax Central Circle -7(1), Mumbai

In the result, all the appeals raised by the assessee are allowed and all the appeals filed by the revenue are dismissed

ITA 2340/MUM/2025[2013-14]Status: DisposedITAT Mumbai22 Aug 2025AY 2013-14

Bench: SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153CSection 250

expenses by taking accommodation entries. In the present case, the allegation is that the appellant has booked back-to-back bogus sales and bogus purchases. Considering that both sales and purchases have been inflated, it doesn't seem that the transactions were carried out forsuppression of income. The issues ... After evaluating the records, the Ld. CIT(A) answered the first question by holding that the assessee has entered into circular transaction of bogus purchase and sales. Further, it was observed that the assessee had duly 9 reflected the profits earned in the books of accounts from such circular transactions

Indrajit Properties Private Limited (in Which Duli Trade & Commodities Pvt Ltd), Mumbai vs. Deputy Commissioner of Income Tax Central Circle -7(1), Mumbai

In the result, all the appeals raised by the assessee are allowed and all the appeals filed by the revenue are dismissed

ITA 2144/MUM/2025[2018-19]Status: DisposedITAT Mumbai22 Aug 2025AY 2018-19

Bench: SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153CSection 250

expenses by taking accommodation entries. In the present case, the allegation is that the appellant has booked back-to-back bogus sales and bogus purchases. Considering that both sales and purchases have been inflated, it doesn't seem that the transactions were carried out forsuppression of income. The issues ... After evaluating the records, the Ld. CIT(A) answered the first question by holding that the assessee has entered into circular transaction of bogus purchase and sales. Further, it was observed that the assessee had duly 9 reflected the profits earned in the books of accounts from such circular transactions

Indrajit Properties Private Limited (in Which Duli Trade & Commodities Pvt Ltd), Mumbai vs. Deputy Commissioner of Income Tax Central Circle 7(1), Mumbai

In the result, all the appeals raised by the assessee are allowed and all the appeals filed by the revenue are dismissed

ITA 2143/MUM/2025[2017-18]Status: DisposedITAT Mumbai22 Aug 2025AY 2017-18

Bench: SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153CSection 250

expenses by taking accommodation entries. In the present case, the allegation is that the appellant has booked back-to-back bogus sales and bogus purchases. Considering that both sales and purchases have been inflated, it doesn't seem that the transactions were carried out forsuppression of income. The issues ... After evaluating the records, the Ld. CIT(A) answered the first question by holding that the assessee has entered into circular transaction of bogus purchase and sales. Further, it was observed that the assessee had duly 9 reflected the profits earned in the books of accounts from such circular transactions

Indrajit Properties Private Limited (in Which Duli Trade & Commodities Pvt Ltd), Mumbai vs. Deputy Commmissioner of Income Tax Central Circle, Mumbai

In the result, all the appeals raised by the assessee are allowed and all the appeals filed by the revenue are dismissed

ITA 2142/MUM/2025[2016-17]Status: DisposedITAT Mumbai22 Aug 2025AY 2016-17

Bench: SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153CSection 250

expenses by taking accommodation entries. In the present case, the allegation is that the appellant has booked back-to-back bogus sales and bogus purchases. Considering that both sales and purchases have been inflated, it doesn't seem that the transactions were carried out forsuppression of income. The issues ... After evaluating the records, the Ld. CIT(A) answered the first question by holding that the assessee has entered into circular transaction of bogus purchase and sales. Further, it was observed that the assessee had duly 9 reflected the profits earned in the books of accounts from such circular transactions

Indrajit Properties Private Limited (in Which Duli Trade & Commodities Pvt Ltd), Mumbai vs. Deputy Commissioner of Income Tax Central Circle -7(1), Mumbai

In the result, all the appeals raised by the assessee are allowed and all the appeals filed by the revenue are dismissed

ITA 2141/MUM/2025[2015-16]Status: DisposedITAT Mumbai22 Aug 2025AY 2015-16

Bench: SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153CSection 250

expenses by taking accommodation entries. In the present case, the allegation is that the appellant has booked back-to-back bogus sales and bogus purchases. Considering that both sales and purchases have been inflated, it doesn't seem that the transactions were carried out forsuppression of income. The issues ... After evaluating the records, the Ld. CIT(A) answered the first question by holding that the assessee has entered into circular transaction of bogus purchase and sales. Further, it was observed that the assessee had duly 9 reflected the profits earned in the books of accounts from such circular transactions

Indrajit Properties Private Limited (in Which Duli Trade & Commodities Pvt Ltd), Mumbai vs. Deputy Commissioner of Income Tax Central Circle -7(1), Mumbai

In the result, all the appeals raised by the assessee are allowed and all the appeals filed by the revenue are dismissed

ITA 2140/MUM/2025[2014-15]Status: DisposedITAT Mumbai22 Aug 2025AY 2014-15

Bench: SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153CSection 250

expenses by taking accommodation entries. In the present case, the allegation is that the appellant has booked back-to-back bogus sales and bogus purchases. Considering that both sales and purchases have been inflated, it doesn't seem that the transactions were carried out forsuppression of income. The issues ... After evaluating the records, the Ld. CIT(A) answered the first question by holding that the assessee has entered into circular transaction of bogus purchase and sales. Further, it was observed that the assessee had duly 9 reflected the profits earned in the books of accounts from such circular transactions

Indrajit Properties Private Limited (in Which Duli Trade & Commodities Pvt Ltd), Mumbai vs. Deputy Commissioner of Income Tax, Central Circle -7(1), Mumbai

In the result, all the appeals raised by the assessee are allowed and all the appeals filed by the revenue are dismissed

ITA 2139/MUM/2025[2013-14]Status: DisposedITAT Mumbai22 Aug 2025AY 2013-14

Bench: SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153CSection 250

expenses by taking accommodation entries. In the present case, the allegation is that the appellant has booked back-to-back bogus sales and bogus purchases. Considering that both sales and purchases have been inflated, it doesn't seem that the transactions were carried out forsuppression of income. The issues ... After evaluating the records, the Ld. CIT(A) answered the first question by holding that the assessee has entered into circular transaction of bogus purchase and sales. Further, it was observed that the assessee had duly 9 reflected the profits earned in the books of accounts from such circular transactions

Assistant Commissioner of Income Tax, Delhi vs. Vijendra Surendra Exports Private Limited, Delhi

ITA 1880/DEL/2025[2012-13]Status: DisposedITAT Delhi22 Aug 2025AY 2012-13

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Sh. Mayank Patawari, AdvFor Respondent: Sh. Manish Gupta, Sr. DR
Section 147Section 148

purchase/sales and notice under Section 148 accordingly was issued. Such assessment was culminated in making addition of Rs.62,96,650/- observing that appellant received bogus purchase bills from M/s Mayank Impex of Rs.52,28,710/- and the bills from M/s Nazar Impex Pvt. Ltd. of Rs.10,67,940/- totaling ... cogent reason has been given by the department for treating the purchases as not being genuine but accepting the sales made against the said bogus purchases as genuine. Therefore, on an overall view of the facts, it is our considered opinion that the Ld. CIT(A) was not justified

Assistant Commissioner of Income Tax, Delhi vs. Vijendra Surendra Exports Private Limited, Delhi

ITA 1871/DEL/2025[2011-12]Status: DisposedITAT Delhi22 Aug 2025AY 2011-12

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Sh. Mayank Patawari, AdvFor Respondent: Sh. Manish Gupta, Sr. DR
Section 147Section 148

purchase/sales and notice under Section 148 accordingly was issued. Such assessment was culminated in making addition of Rs.62,96,650/- observing that appellant received bogus purchase bills from M/s Mayank Impex of Rs.52,28,710/- and the bills from M/s Nazar Impex Pvt. Ltd. of Rs.10,67,940/- totaling ... cogent reason has been given by the department for treating the purchases as not being genuine but accepting the sales made against the said bogus purchases as genuine. Therefore, on an overall view of the facts, it is our considered opinion that the Ld. CIT(A) was not justified

Assistant Commissioner of Income Tax, Delhi vs. Vijendra Surendra Exports Private Limited, Delhi

ITA 1870/DEL/2025[2010-11]Status: DisposedITAT Delhi22 Aug 2025AY 2010-11

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Sh. Mayank Patawari, AdvFor Respondent: Sh. Manish Gupta, Sr. DR
Section 147Section 148

purchase/sales and notice under Section 148 accordingly was issued. Such assessment was culminated in making addition of Rs.62,96,650/- observing that appellant received bogus purchase bills from M/s Mayank Impex of Rs.52,28,710/- and the bills from M/s Nazar Impex Pvt. Ltd. of Rs.10,67,940/- totaling ... cogent reason has been given by the department for treating the purchases as not being genuine but accepting the sales made against the said bogus purchases as genuine. Therefore, on an overall view of the facts, it is our considered opinion that the Ld. CIT(A) was not justified

Shivam Betelnut Private Limited, Delhi vs. ACIT, Circle-22(2), New Delhi

In the result, the appeals of the assessee in ITA Nos

ITA 1297/DEL/2024[2020-21]Status: DisposedITAT Delhi22 Aug 2025AY 2020-21

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 147Section 69

after conclusion of search forwarded information Page 2 of 10 ITA No. 1296 & 1297/DEL/2024 [A.Ys. 2017-18 & 2020-21] Shivam Betelnut Vs.ACIT regarding bogus purchases amounting to Rs. 73,83,76,480/- during the year under consideration. 6. On the basis of the information and on enquiry the assessing officer ... assessment order or the appellate order passed consequent to the search by the GST authorities in its favour to hold that the determination of bogus purchases of Rs.73,86,76,480 was revised subsequently or reduced by the appellate forum. On the date of passing the assessment order, there were

Shivam Betelnut Private Limited, Delhi vs. ACIT, Circle-22(2), Delhi

In the result, the appeals of the assessee in ITA Nos

ITA 1296/DEL/2024[2017-18]Status: DisposedITAT Delhi22 Aug 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 147Section 69

after conclusion of search forwarded information Page 2 of 10 ITA No. 1296 & 1297/DEL/2024 [A.Ys. 2017-18 & 2020-21] Shivam Betelnut Vs.ACIT regarding bogus purchases amounting to Rs. 73,83,76,480/- during the year under consideration. 6. On the basis of the information and on enquiry the assessing officer ... assessment order or the appellate order passed consequent to the search by the GST authorities in its favour to hold that the determination of bogus purchases of Rs.73,86,76,480 was revised subsequently or reduced by the appellate forum. On the date of passing the assessment order, there were

Pravinbhai Mohanbhai Vadi, Jamnagar vs. Pr. Commissioner of Income Tax, Jamnagar

In the result, appeal filed by the assessee is allowed

ITA 102/RJT/2025[2021-22]Status: DisposedITAT Rajkot21 Aug 2025AY 2021-22

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.102/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2021-22 Pravinbhai Mohanbhai Vadi The Pr. Commissioner Of बनाम Flat No.1, Prabhudeep Apartment Income Tax, Jamanagar. Air Force-2 Road Vs. Jamnagar. Pan : Agzpv6946P (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

For Appellant: Shri Chetan Agarwal, ld.ARFor Respondent: Shri Sanjay Punglia, ld.CIT-DR
Section 115BSection 142(1)Section 143(3)Section 263Section 263oSection 69C

purchases made by the assessee were bogus, and therefore, entire addition should be made in the hands of the assessee in respect of bogus purchases instead of 25% addition made by the AO on account of bogus purchases, which is not acceptable, because only profit element embedded in the purchases ... acceptable. The AO has examined all the documentary evidences submitted by the assessee and took a plausible view and added 25% of the bogus purchases. Therefore, such assessment order is neither erroneous nor prejudicial to the interest of the revenue, therefore, the jurisdiction exercised

Jewels Emporium A Legacy, Jaipur vs. ACIT, CC-1, Jaipur

In the result, the appeal of the assessee stands allowed

ITA 1215/JPR/2024[2009-10]Status: DisposedITAT Jaipur21 Aug 2025AY 2009-10

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Tarun Mittal, C.AFor Respondent: Mrs. Anita Rinesh, JCIT,Sr.-DR a
Section 143(3)Section 145(3)

rate would come to 34.91%. In AY 2008-09, GP rate shown by assessee is 35.02% and trading addition made by way of bogus purchases were deleted by CIT(A) and appeal filed by revenue was disposed off in view of tax effect being lower than the monetary limit ... specific mention of the assessee in the statements, so as to infer that assessee was amongst the 95% beneficiaries who had made bogus purchases form M/s Clarity Gold (P) ltd, nor that the said entity had denied supply of goods to the assessee. Further the said statements relied upon

Assistant Commissioner-19(1), Mumbai vs. Kdm Impex, Mumbai

In the result, appeal of the revenue is dismissed, in terms of our

ITA 3040/MUM/2025[2012-13]Status: DisposedITAT Mumbai21 Aug 2025AY 2012-13

Bench: Shri Amit Shukla & Shri Arun Khodpiaआयकर अपील सं. / Ita No.3040/Mum/2025 निर्धारण वर्ष / Assessment Year :2012-13 The Assistant Commissioner Of Income Tax-19(1), Mumbai ........अपीलार्थी / Appellant बनाम / V/S. M/S. Kdm Impex 506, 5Th Floor, Piramal Chambers, Lalbag, Mumbai-400 012 Pan : Aadfk2444F ......प्रत्यर्थी / Respondent Assessee By : None Revenue By : Shri Himanshu Joshi, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 20.08.2025 घोषणा की तारीख / Date Of Pronouncement : 21.08.2025 2 Acit-19(1), Mumbai Vs. M/S. Kdm Impex

For Appellant: NoneFor Respondent: Shri Himanshu Joshi, Sr. DR
Section 37Section 68

facts and circumstances of the case and in law, Ld. CITIA) is right in restricting the addition to 3% of the total bogus purchase as against addition by the AO of 100% of bogus purchases even when Ld. CIT(A) itself agreed with the conclusion drawn by AO that ... Gujarat reversing the order of Ld. CIT(A). Ahmedabad, in the case of N K Protein Ltd. which is on the similar issue of bogus purchases and that this order of the Hon'ble High Court of Gujarat disallowing 100% of the bogus purchases was already law of the land

Basanth Lal Sah, Hyderabad vs. ITO., Ward-11(1), Hyderabad

ITA 612/HYD/2025[2021-22]Status: DisposedITAT Hyderabad20 Aug 2025AY 2021-22

Bench: Us :

Section 133(6)Section 143(3)

without providing the appellant any documentary evidence. 6. The action of the Ld. CIT(A) in confirming the addition made by the AO as bogus purchases even though the sales were not disputed, no discrepancies were found in stock and also, audited books of accounts were not rejected ... were in turn based on inferences driven by suspicion, assumptions, conjectures and surmises. 9. The Ld. CIT(A) erred in upholding the additions alleging bogus purchases solely on the grounds that the creditors did not respond to notice issued u/s 133(6) of the Act and that the creditors

Income Tax Officer, C R Building Delhi vs. Spectra Televentures Private Limited, South Delhi

In the result, the appeal of the Revenue is dismissed

ITA 225/DEL/2024[2021-22]Status: DisposedITAT Delhi20 Aug 2025AY 2021-22

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2021-22] Ito, Vs Spectra Televentures Pvt.Ltd., Ward-24(1), B-170B, Gf, Khasra No.82, 83, C.R.Building, I.P.Estate, 84, 86, 91-94, Maidan Gari Delhi-110002. Extension, South Delhi, Delhi-110068. Pan-Aancs0303C Appellant Respondent Revenue By Shri Mahesh Kumar, Cit Dr Assessee By Ms. Rano Jain, Adv., Mansi Jain, Ca, Pranshu Singhal, Ca, Sakshi Rustagi, Adv. & Mudit Dewan, Adv. Date Of Hearing 27.05.2025 Date Of Pronouncement 20.08.2025 Order

Section 142(1)Section 143(2)Section 143(3)Section 250

Issue of non-genuine purchases in his order. The order of the A.O. is not para-wise, the relevant portions related to such bogus purchases are re-produced as under: - “The assessee had incurred purchases amounting to Rs. 12,88,63,261/-for the year under consideration. The assessee

Peeyush Agarwal, Jaipur, Rajasthan vs. ITO, Ward 1(5), Jaipur, Rajasthan

In the result Ground and 1 and 2 raised by the assessee are allowed

ITA 488/JPR/2025[2017-18]Status: DisposedITAT Jaipur19 Aug 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Vijay Goyal, C.A. &For Respondent: Mrs. Alka Gautam, CIT
Section 115BSection 143(2)Section 143(3)Section 145(3)Section 250Section 68Section 69A

lower authorities neither found any concrete and conclusive evidence of back dating of the entries of sale, evidence of bogus sales, evidence of bogus purchases, evidence of non-existing of 21 Peeyush Agarwal, Jaipur. stock as on the date of sales and non-existing cash in the books of account ... fact the AO neither found any concrete and conclusive evidence of back dating of the entries of sale, evidence of bogus sales, evidence of bogus purchases, and non­existing cash balance in the books of account. The AO did not even reject the books of accounts of the appellant under

Vinod Kumar, Karnal vs. ITO Ward-1, Karnal

Appeal is partly allowed

ITA 4344/DEL/2025[2013-14]Status: DisposedITAT Delhi19 Aug 2025AY 2013-14

Bench: Sh. Satbeer Singh Godaraita No. 4344/Del/2025 : Asstt. Year : 2013-14 Vinod Kumar Prop. Of Vinod Vs Income Tax Officer, Enterprises, R/O H. No. 920, Ward-1, Sector-13, Karnal, Karnal, Haryana-132001 Haryana-132001 (Appellant) (Respondent) Pan No. Adepk5811G Assessee By: Sh. Rajeev Sachdeva, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 19.08.2025 Date Of Pronouncement: 19.08.2025 Order This Assessee’S Appeal For Assessment Year 2013-14, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1076659712(1) Dated 03.06.2025, In Proceedings U/S 143(3) R.W.S. 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Rajeev Sachdeva, CAFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 143(3)Section 69C

have given my thoughtful consideration to the assessee’s and the Revenue vehement rival submissions reiterating their respective stands. Coming to the impugned alleged bogus purchase disallowance, the department could hardly dispute that the assessee’s corresponding sales have nowhere been doubted as duly declared in the P&L account ... corresponding relevant supportive evidence in both the lower proceedings. It is thus deemed appropriate in these peculiar facts that the assessee’s impugned bogus purchases of Rs.15,50,000/- deserve to be disallowed at a lump sum rate of 10% with a rider that the same shall not be treated