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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

Himesh Hiralal Mehta, Mumbai vs. Income Tax Officer -25(2)(4), Mumbai

In the result, the appeal of the assessee is allowed partly for statistical purposes

ITA 1123/MUM/2025[2009-10]Status: DisposedITAT Mumbai19 Jun 2025AY 2009-10

Bench: Shri Om Prakash Kant () & Shri Anikesh Banerjee () Assessment Year: 2009-10 Himesh Hiralal Mehta National Faceless Assessment 3 Vallabh Niwas No 1, Centre, Delhi Ito 34(2)(1), Malavia Road, Vile Parle (East), Vs. Kautilya Bhavan, C-41, Mumbai - 40005 G Block, Bandra Kurla Complex, Bandra (East), Mumbai-400051 Pan No. Aaepm 4744 M Appellant Respondent

For Appellant: Ms. Neha ParanjpeFor Respondent: Mr. Hemanshu Joshi, CIT-DR
Section 133(6)Section 143(1)Section 148Section 69C

appeal of the Appellant and there by confirming the disallowance of Rs.63.29,036/- under section 69C of the Act on account of alleged bogus purchases without appreciating the facts and circumstances of the case. The disallowance made under section 69C of the Act is not justified and the same requires ... issued for commencing reassessment proceedings. During the re-assessment proceeding, the Assessing Officer issued notice u/s 133(6) of the Act to the alleged bogus purchase parties who had issued accommodation entries bills to the assessee, but said notices issued were returned un-served by the Postal Authorities with

Rishabh Consumer Products Private Limited, Vashi vs. DCIT 15(3)(1), Mumbai

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

ITA 5902/MUM/2024[2009-2010]Status: DisposedITAT Mumbai19 Jun 2025AY 2009-2010

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeassessment Year : 2009-10 Rishabh Consumer Products Dcit-15(3)(1), Private Limited, Room No. 451, C/450-4 Ttc Midc Pawne, Vs. Aayakar Bhavan, Thane, Navi Mumbai, Mumbai-400020. Mumbai-400705. Pan : Aaccr8140D (Appellant) (Respondent)

For Appellant: Shri Dharan GandhiFor Respondent: Shri Annavaram Kosuri
Section 143(1)Section 144rSection 147Section 148Section 234ASection 271Section 274Section 61Section 64

erred in upholding the addition of Rs. 1,02,28,225/- in respect of alleged bogus purchases. 5. The Ld. AO has erred in assessing total income at Rs. 1,90,85,458/- 6. The Ld. AO has erred in not considering the revised return of income filed ... coupled with statements of these parties admitting the fact of issuance of bogus bills, the purchases made from the alleged parties are treated as „bogus purchases‟. The Investigation Wing of the Income Tax Department has provided these details after due verification and confirmation. The facts about the hawala dealers

ITO-19(3)(1), Mumbai vs. Sheetal Dilip Jain, Mumbai

The appeal of the revenue are partly allowed

ITA 2658/MUM/2024[2018-19]Status: DisposedITAT Mumbai19 Jun 2025AY 2018-19

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Dhiren Talati, ARFor Respondent: Shri Swapnil Choudhary, Sr.DR
Section 68

that CIT(A)'s own action of sustaining Wafa's profit implies he agreed with the AO's methodology of profit estimation for bogus purchases. Therefore, the ld DR submited that CIT(A) should not have curtailed the addition and at a minimum, the profit addition on unverified purchases should

Sheetal Dilip Jain, Mumbai vs. Commissioner of Income Tax Appeas_NFAC, Mumbai

The appeal of the revenue are partly allowed

ITA 2626/MUM/2024[2018-19]Status: DisposedITAT Mumbai19 Jun 2025AY 2018-19

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Dhiren Talati, ARFor Respondent: Shri Swapnil Choudhary, Sr.DR
Section 68

that CIT(A)'s own action of sustaining Wafa's profit implies he agreed with the AO's methodology of profit estimation for bogus purchases. Therefore, the ld DR submited that CIT(A) should not have curtailed the addition and at a minimum, the profit addition on unverified purchases should

Mapss Fats and Proteins Private Limited, Raipur vs. Income Tax Officer, Ward 1(2), Raipur, Aaykar Bhawan Civil Lines

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

ITA 246/RPR/2025[2009-10]Status: DisposedITAT Raipur18 Jun 2025AY 2009-10

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.246/Rpr/2025 "नधा"रण वष" /Assessment Year : 2009-10 Mapss Fats & Proteins Private Limited Shanti Sadan, Chouby Colony, Raipur (C.G.)-492 001 Pan: Aafcm7263D .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(2), Raipur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Vikram Chhabda, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 131Section 133ASection 147Section 148

Assessment was completed by the A.O u/s.147 of the Act, dated 31.12.2016, wherein an addition of Rs.9,46,500/- was made on account of bogus purchases which comprises of viz. (i) disallowance of 25% of the total bogus purchases : Rs.7,00,500/- i.e. (25% of Rs.28 ... facts and circumstances needs proper verification by the department so to find out whether any lawful taxes remain unpaid to the department due to bogus purchase transaction by the assessee which shall be within purview of tax evasion amounting to fraud to the revenue and in such case, fraud vitiates

Deputy Commissioner of Income Tax-1(1), Raipur vs. Shanta Techno Private Limited, Raipur

ITA 155/RPR/2025[2018-19]Status: DisposedITAT Raipur18 Jun 2025AY 2018-19

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 155/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19)

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 142(1)Section 147Section 148Section 250Section 69C

circumstance of the case and in law, the Ld. CIT(A) was justified in restricting addition to the extent of 12.5% of bogus purchases instead of disallowing 100% of the bogus purchases relying upon the decision of Hon'ble High Court of Bombay in the case of PCIT ... matter, the Ld. AO had possess the information that, in the year under consideration, the assessee had received accommodation entries in the form of bogus purchases amounting to Rs.76,21,830/- from M/s Shree Shyam Sales Corporation, who was indulged in the activity of issuance of bogus bills in respect

Shri Amit Jayantilal Doshi, Mumbai vs. ITO Ward 19(1)(1), Mumbai

In the result, the appeal is allowed

ITA 2950/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Jun 2025AY 2018-19

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Reepal Tralshawala, ARFor Respondent: Shri Aditya Rai (Sr. DR)
Section 147Section 148Section 148ASection 151Section 69C

Taman Jewels P. Lad and the same is not bogus, as alleged and the Appellant is not beneficiary of any such alleged bogus purchases. b. complete details and documentary evidences of purchase made from M/s Tanman Jewels P. Ltd. and nexus of sale to various parties were furnished including stock

ITO-1(2)(3), Mumbai vs. Macrocosm Industries Private Limited, Mumbai

In the result, all the grounds of

ITA 4708/MUM/2024[2012-13]Status: DisposedITAT Mumbai18 Jun 2025AY 2012-13

Bench: Shri Pawan Singh & Shri Prabhash Shankar(Physical Hearing) Ito – 1(2)(3), Mumbai Macrocosm Industries Private Limited Room No. 527, Aayakar Bhavan Vs 205, Jolly Bhavan No. 2, Near Marine M K Road, Mumbai – 400020. Line, Mumbai – 400020. Pan: Aafcm0249M Appellant / Revenue Respondent / Assessee

Section 143(1)Section 144Section 254(1)Section 271(1)(b)Section 41(1)Section 43B

facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in restricting the disallowance of non-genuine and bogus purchases shown by the assessee company to 5% only without appreciating the fact that the purchases were not proved to be genuine and the assessee

ITO 5(2)(1), Mumbai vs. Mokxa Diamond Private Limited, Mumbai

In the result, the appeal filed by the revenue bearing ITA No

ITA 2006/MUM/2024[2013-14]Status: DisposedITAT Mumbai18 Jun 2025AY 2013-14

Bench: SHRI VIKRAM SINGH YADAV (Accountant Member), SHRI ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri Bharat KumarFor Respondent: Shri Annavaram Kosuri SR.AR
Section 133(6)Section 144BSection 147Section 148Section 250Section 68Section 69C

facts of the case, an addition of Rs. 1,12,80,950/- was made in the case of the appellant on account of bogus purchases and advance of similar amounts of Rs.56,40,475/- from M/s Anjani Diam Pvt. Ltd. by the Ld. AO vide his order u/s 147 r.w.s ... transactions of advance payment made against purchase of goods and advance receipt for sale of goods and has made addition by considering to be bogus purchases under section 690 and unexplained cash credit under section 68 of the Income Tax Act, 1961. The appellant has explained that the appellant

Gangadhar Nagorao Nikam, Nagpur vs. DCIT ACIT Circle - 1 Nagpur, Nagpur

In the result, appeal of the assessee is allowed

ITA 458/NAG/2024[2009-10]Status: DisposedITAT Nagpur17 Jun 2025AY 2009-10

Bench: Shri N.K. Choudhry & Shri K.M. Roy

For Appellant: Smt. Veena Agrawal, CAFor Respondent: Shri Anand Nagrale, Sr.DR
Section 144Section 250

made the addition of ` 7,29,222/– being 13.02% of the gross purchases of ` 56,00,790/–, on account of disallowance of bogus purchases. The assessee being aggrieved, challenged the said addition before the Ld. Commissioner, however, could not get any relief, as the Ld. Commissioner affirmed the aforesaid addition ... circumstances of the case. It appears from the orders passed by the lower authorities that it is not the complete case of the bogus purchases and admittedly the A.O. has not disputed the sale made of the alleged bogus purchases. Therefore, to cut–short the litigation and for substantial justice

Shri Trushar Parimalbhai Shah, Bhavnagar vs. The Income Tax Officer, Ward-1(5), Bhavnagar

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 1848/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad17 Jun 2025AY 2012-13

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2012-13

Section 143(3)Section 147Section 68

Year: 2012-13 Shri Trushar Parimalbhai Shah vs. ITO Page 3 of 5 addition of Rs.1,00,51,000/- was made in respect of bogus purchases. Further, information was also received regarding accommodation entry taken by the assessee from M/s. Sankalp Traders and M/s. Yashasvi Enterprise and the total amount

Maa Ashapura Developers, Mumbai vs. Income Tax Officer, Ward 42(1)(3), Mumbai

In the result, the appeal filed by the assessee bearing ITA No

ITA 276/MUM/2025[2012-13]Status: DisposedITAT Mumbai13 Jun 2025AY 2012-13

Bench: SHRI VIKRAM SINGH YADAV (Accountant Member), SHRI ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri Vimal Punmiya (CA)For Respondent: ShriAnnavaram Kosuri SR.AR
Section 139(1)Section 142(1)Section 143(3)Section 250Section 69C

cash 3 ITA 276/Mum/2025 Maa Ashapura Developers on commission basis. It is found that the assessee has introduced accommodation entries by way of bogus purchases from the following parties:- Sr.No. Name of the party VAT / TIN Amount (Rs.) 1 M/s Orient Cement 27770246923V 5695736 2 M/s Dhanlaxmi Enterprises 27600222233V

Shivani Tayal, New Delhi vs. Income Tax Officer, Ward 49(1), New Delhi, Delhi

In the result, Appeal of the Assessee is allowed

ITA 5833/DEL/2024[2014-15]Status: DisposedITAT Delhi13 Jun 2025AY 2014-15

Bench: Shri M. Balaganesh & Sh. Yogesh Kumar U.S.Shivani Tayal Vs. Income Tax Officer, C-27, Shop No.9-10, Ward 49(1), Mansarovar Garden, New New Delhi Delhi Pan: Andpt8647E Appellant Respondent Assessee By Advocate Ragini Handa Revenue By Sh. Sahil Kumar Bansal, Sr. Dr Date Of Hearing 06/05/2025 Date Of Pronouncement 13/06/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of The Cit(A)/National Faceless Appeal Centre (‘Nfac’ For Short) Dated

Section 10(38)Section 148Section 148ASection 151Section 250Section 69C

addition made by the Ld. AO amounting to Rs. 1,35,21,188/- under section 69C of the Act by holding the same as bogus purchases from Shri Amit Kumar (Prop M/s Rishabh Trading Company). 4. That on the facts and circumstances of the case ... sale of scripts during the impugned AY and also that the amount of Rs. 1,35,21,188 represents bogus purchases. 7. That on the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in sustaining the addition despite the fact that notice

Dy. Commissioner of Income Tax, Central Circle-27, Delhi vs. Nkg Infrastructure Limited, Delhi

In the result, the appeal filed by the assessee is partly allowed and the appeal filed by the Revenue is dismissed

ITA 5109/DEL/2024[2013-14]Status: DisposedITAT Delhi13 Jun 2025AY 2013-14

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Shri Rajat Jain, CAFor Respondent: Shri Sunil Kumar Yadav, CIT DR
Section 143(2)Section 143(3)Section 148Section 153ASection 68Section 69C

following the decision of his predecessor for AY 2014-15 and observed that assessee has further made sales of material purchased from the bogus purchases from the bogus entities which are also appearing in the same list of 29 companies operated and managed by Anil Kumar Singhal. Accordingly, he treated ... both purchases as well as sales as bogus and proceeded to sustain the addition of 3% of the bogus purchases as income of the assessee and estimated the income of Rs.4,02,68,480/- as unexplained expenditure u/s 69C of the Act. 5. Aggrieved with the above order, both

Nkg Infrastructure Limited, New Delhi vs. DCIT, Central Circle-27, Delhi

In the result, the appeal filed by the assessee is partly allowed and the appeal filed by the Revenue is dismissed

ITA 4749/DEL/2024[2013-14]Status: DisposedITAT Delhi13 Jun 2025AY 2013-14

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Shri Rajat Jain, CAFor Respondent: Shri Sunil Kumar Yadav, CIT DR
Section 143(2)Section 143(3)Section 148Section 153ASection 68Section 69C

following the decision of his predecessor for AY 2014-15 and observed that assessee has further made sales of material purchased from the bogus purchases from the bogus entities which are also appearing in the same list of 29 companies operated and managed by Anil Kumar Singhal. Accordingly, he treated ... both purchases as well as sales as bogus and proceeded to sustain the addition of 3% of the bogus purchases as income of the assessee and estimated the income of Rs.4,02,68,480/- as unexplained expenditure u/s 69C of the Act. 5. Aggrieved with the above order, both

Kishan Ram Vishnoi, Bhopal vs. ITO-3(1), Bhopal

Appeals are partly allowed in terms mentioned

ITA 404/IND/2023[2010-2011]Status: DisposedITAT Indore10 Jun 2025AY 2010-2011

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 147

Total Additions of Rs.50,86,050/- proposed by the Id. A.O. on account of Non Genuine and Bogus Purchase Bills. Therefore, above Additions of Rs.4,06,884/- deserves to be deleted. 02. The Hon'ble CIT-Appeals has erred on facts and in law in holding that delivery challans ... purchases. During first-appeals, the CIT(A), relying upon certain judicial\ rulings, restricted disallowances to gross-profit element @ G.P. rate of 8% of bogus purchases and thereby reduced disallowances to Rs.4,06,884/- [8% of Rs.50,86,050/-] and Rs.6,17,235/- [8% of Rs.73,15,444/-] respectively

Kishan Ram Vishnoi, Bhopal vs. ITO-3(1), Bhopal

Appeals are partly allowed in terms mentioned

ITA 403/IND/2023[2009-2010]Status: DisposedITAT Indore10 Jun 2025AY 2009-2010

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 147

Total Additions of Rs. 50,86,050/- proposed by the ld. A.O. on account of Non Genuine and Bogus Purchase Bills. Therefore, above Additions of Rs. 4,06,884/- deserves to be deleted. 02. The Hon'ble CIT-Appeals has erred on facts and in law in holding that delivery ... purchases. During first-appeals, the CIT(A), relying upon certain judicial rulings, restricted disallowances to gross-profit element @ G.P. rate of 8% of bogus purchases and thereby reduced disallowances

Principal Commissioner of Income Tax 5 Kolkata vs. Advance Engineering Corporation

In the result, the appeal is allowed and the

ITAT/266/2024HC Calcutta09 Jun 2025

Bench: : The Hon'Ble The Chief Justice T.S Sivagnanam -A N D- Hon'Ble Justice Chaitali Chatterjee (Das) Date : 9Th June, 2025.

Section 143(3)Section 147Section 260ASection 69C

circumstances of the case, the learned Tribunal was justified in law to restrict the addition to only 8% of the total bogus purchases even after taking cognizance of the fact that the respondent assessee has failed to establish the genuineness of the purchases? b. Whether on the facts ... parties which clearly establishes the doubt to arrive at a 2 conclusion that the respondent assessee had availed accommodation entries in the form of bogus purchases which thereby gives rise to perversity in the decision making process?” We have heard Mr. Amit Sharma, learned senior standing counsel for the appellant/revenue

Global Extrusions Pvt. Ltd., Jamnagar vs. The Pr. CIT, Jamnagar

ITA 203/RJT/2024[2013-14]Status: DisposedITAT Rajkot09 Jun 2025AY 2013-14

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.203/Rjt/2024 "नधा"रणवष" / Assessment Year: (2013-14) (Hybrid Hearing) Global Extrusions Private Limited. Vs. Pcit Jamnagar, Ca Govind Sonecha Taranjali Building, “S&A House”, Near Golden City, Jamnagar 361008 80Ft Road, Khodiyar Colony, B/H Saru Section Police Headquarters, Jamnagar 361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabcm4319E (Appellant) (Respondent) Appellant By : Ms. Amoli Gusani, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. (Cit)Dr Date Of Hearing : 19/03 /2025 Date Of Pronouncement : 09/06/2025

For Appellant: Ms. Amoli Gusani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. (CIT)DR
Section 139Section 142(1)Section 144BSection 147Section 147rSection 148Section 263

learned PCIT has erred in law vide para 7 and 8 of his Order by treating the purchase made from Ankit Metals, as Bogus Purchase and rendering the said purchase transactions to be unexplained. 3. The learned PCIT has erred in law vide para 9 and 10 of his Order ... appeal before us. Global extrusions pvt. Ltd. 6. During the course of hearing the Ld. AR has submitted that a notice issued on account bogus purchase/ accommodated entry however the case was reopened u/s 148 of the Act. only on this ground. The assessee has replied to notice

Nareshbhai Arjanbhai Lathiya, Surat vs. ACIT, Circle-3(3), Surat

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

ITA 909/SRT/2024[2012-13]Status: DisposedITAT Surat09 Jun 2025AY 2012-13

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita No.909/Srt/2024 Assessment Year: (2012-13) (Hybrid Hearing) Nareshbhai Arjanbhai Lathiya, Vs. Acit, 317, Regal Diamond Centre, Tata Circle – 3(3), Road No. 1 &2 Opera House, Surat Mumbai - 400004 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Adlpp8388A (Appellant) (Respondent) Appellant By Shri P. M. Jagasheth, Ca Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 23/04/2025 Date Of Pronouncement 09/06/2025

Section 132Section 133(6)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 69C

course of search and seizure operation u/s 132 of the Act, it was admitted by these groups that they were providing accommodation entries of bogus purchase to various beneficiaries. The assessee had made non-genuine purchases of ITA No.909/SRT/2024/AY.2012-13 Nareshbhai Arjanbhai Lathiya Rs.8,27,67,788/- from M/s Kailash ... assessee has filed appeal before the Tribunal. The appellant has challenged both reopening as well as merit of addition @ 100% of the bogus purchase of Rs.8,27,67,788/-, as upheld by CIT(A). The ld. AR has relied on the decisions Gujarat High Court in cases of PCIT