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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

Mehulkumar Sanatkumar Gandhi, Mehsana vs. The ITO, Ward-1, Mehsana

In the result, the appeal field by the assessee is treated as allowed for statistical purpose

ITA 22/AHD/2026[2021-22]Status: DisposedITAT Ahmedabad19 Feb 2026AY 2021-22

Bench: Him Arising Out Of The Assessment Order Passed Under Section 143(3) R.W.S. 144B Of The Income Tax Act, 1961

Section 133(6)Section 143(3)

replied to the summons issued u/s. 133(6), therefore the assessing officer treated the purchases made by the assessee from the above parties as bogus purchase and made addition of Rs.6,34,81,280/- and demanded tax thereon. 4. Aggrieved against the same, assessee filed an appeal before ... style of Padmavati Enterprises. Thus the assessee only a name lender and Shri Hitesh Vishnubhai Patel operated the bank accounts and made the bogus purchases against which the criminal complaint is lodged with the Police Authorities and recently his statement was recorded and waiting for the FIR to be registered

Dy Commissioner of Income Tax 2 1 1 Mumbai, Mumbai vs. Kimiya Engineers Private Limited, Mumbai

In the result, the appeals filed by the Revenue are dismissed

ITA 8120/MUM/2025[2014-15]Status: DisposedITAT Mumbai19 Feb 2026AY 2014-15

Bench: IN THE INCOME TAX APPELLATE TRIBUNAL, ‘E’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 131Section 133ASection 143(3)Section 153A

against the action of the learned CIT(A) in restricting the addition made by the Assessing Officer on account of alleged non-genuine or bogus purchases by estimating the profit element embedded therein at 15%, instead of sustaining the disallowance of the entire purchases amounting to 100% as had been ... identical to the facts for AY 2011-12, as discussed above. The appellant has challenged the addition made u/s 69C on account of bogus purchases from the parties which were identified by Sales Tax Department as being accommodation entry providers. The grounds of appeal and the submission made in support

Dy Commissioner of Income Tax 2 1 1 Mumbai, Mumbai vs. Kimiya Engineers Private Limited, Mumbai

In the result, the appeals filed by the Revenue are dismissed

ITA 8119/MUM/2025[2013-14]Status: DisposedITAT Mumbai19 Feb 2026AY 2013-14

Bench: IN THE INCOME TAX APPELLATE TRIBUNAL, ‘E’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 131Section 133ASection 143(3)Section 153A

against the action of the learned CIT(A) in restricting the addition made by the Assessing Officer on account of alleged non-genuine or bogus purchases by estimating the profit element embedded therein at 15%, instead of sustaining the disallowance of the entire purchases amounting to 100% as had been ... identical to the facts for AY 2011-12, as discussed above. The appellant has challenged the addition made u/s 69C on account of bogus purchases from the parties which were identified by Sales Tax Department as being accommodation entry providers. The grounds of appeal and the submission made in support

Dy Commissioner of Income Tax 2 1 1 Mumbai, Mumbai vs. Kimiya Engineers Private Limited, Mumbai

In the result, the appeals filed by the Revenue are dismissed

ITA 8118/MUM/2025[2011-12]Status: DisposedITAT Mumbai19 Feb 2026AY 2011-12

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 131Section 133ASection 143(3)Section 153A

against the action of the learned CIT(A) in restricting the addition made by the Assessing Officer on account of alleged non-genuine or bogus purchases by estimating the profit element embedded therein at 15%, instead of sustaining the disallowance of the entire purchases amounting to 100% as had been ... identical to the facts for AY 2011-12, as discussed above. The appellant has challenged the addition made u/s 69C on account of bogus purchases from the parties which were identified by Sales Tax Department as being accommodation entry providers. The grounds of appeal and the submission made in support

Chandan Dhingadmal Jain, Mumbai, Maharashtra vs. ITO, Ward 19(1)(1), Mumbai, Maharashtra

In the result, both the appeals by the assessee are allowed

ITA 8074/MUM/2025[2011-12]Status: DisposedITAT Mumbai19 Feb 2026AY 2011-12

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: NoneFor Respondent: Shri Virabhadra Mahajan, Sr. DR
Section 143(3)Section 147Section 148Section 250Section 271(1)(c)

ferrous metals. Pursuant to information received from the DGIT (Investigation) Wing, Mumbai, that the assessee is a beneficiary of accommodation entry transactions of bogus purchases, notices under section 148 of the Act were issued, and proceedings under section 147 of the Act were initiated. Vide assessment order passed under section ... passed in ITAs No. 1308 and 1307/Mum/2018, for the assessment years 2010–11 and 2011–12, restricted the disallowance to 5% of the bogus purchases and thus granted partial relief to the assessee. 4. In the meanwhile, penalty proceedings under section 271(1)(c) of the Act were initiated separately

Chandan Dhingadmal Jain, Mumbai vs. ITO, Ward 19(1)(1), Mumbai, Maharashtra

In the result, both the appeals by the assessee are allowed

ITA 8073/MUM/2025[2010-11]Status: DisposedITAT Mumbai19 Feb 2026AY 2010-11
Section 143(3)Section 147Section 148Section 250Section 271(1)(c)

ferrous metals. Pursuant to information received from the DGIT (Investigation) Wing, Mumbai, that the assessee is a beneficiary of accommodation entry transactions of bogus purchases, notices under section 148 of the Act were issued, and proceedings under section 147 of the Act were initiated. Vide assessment order passed under section ... passed in ITAs No. 1308 and 1307/Mum/2018, for the assessment years 2010–11 and 2011–12, restricted the disallowance to 5% of the bogus purchases and thus granted partial relief to the assessee. 4. In the meanwhile, penalty proceedings under section 271(1)(c) of the Act were initiated separately

Ankur Jain, Dhapa vs. ACIT Circle-29, Kolkata, Gariahat

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

ITA 1814/KOL/2025[2018-2019]Status: DisposedITAT Kolkata18 Feb 2026AY 2018-2019

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2018-19 Ankur Jain……………….....……..………………….……….……….……Appellant 5, Jbs Haldar Avenue, Silver Spring, Kolkata-700105. [Pan: Arzpj2451J] Vs. Acit, Circle-29, Kolkata…...……...…………………….....……...…..…..Respondent Appearances By: Shri Souvik Guha, Advocate, Appeared On Behalf Of The Appellant. Shri Prabhakar Prakash Ranjan, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 11, 2026 Date Of Pronouncing The Order : February 18, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.09.2024 Of The Nfac, Delhi Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2018– 19. 2. The Appeal Has Been Filed By The Assessee With A Delay Of 254 Days & The Assessee Has Filed An Affidavit For Condonation Of The Delay. After Going Over The Said Affidavit, We Find Sufficient Reasons Behind The Delay & Consequently, The Delay In Filing The Appeal Is Hereby Condoned & We Proceed To Dispose Of The Appeal On Merits.

Section 250Section 69C

facts of the case are that the case of the assessee was reopened and the Assessing Officer found that the assessee claimed Ankur Jain bogus purchases from shell entities through bogus transactions. After considering the submission of the assessee, the Assessing Officer added Rs.5,89,01,108/-as variation

Income Tax Officer-41.2.2, Mumbai vs. In Coach Builders, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 7993/MUM/2025[2009-10]Status: DisposedITAT Mumbai18 Feb 2026AY 2009-10

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailincome Tax Officer, Ward – 41(2)(2) Room No.834, 8Th Floor, Kautilya Bhawan, Bandra Kurla Complex, Mumbai - 400051 ............... Appellant Pan: Aaafi5110R V/S In Coach Builders, Plot No.1A, L.B.S Marg, Vikhroli (W), ……………… Respondent Mumbai- 400083

For Appellant: NoneFor Respondent: Shri Virabhadra Mahajan, Sr. DR
Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 69

from the office of DGIT (Inv.) Mumbai, and the Sales Tax Authority that the assessee is a beneficiary of an accommodation entry transaction of bogus purchases, proceedings under section 147 were initiated, and notice under section 148 of the Act was issued. Vide order dated 13.03.2014 passed under section ... Thus, it is evident from the record that the AO made the addition on account of bogus purchases on an estimated basis of 20%, which was further reduced by the Tribunal to 15%. Therefore, the entire addition for the year under consideration has been made solely on the basis

ACIT-CC-3(1), Mumbai vs. I Ahmed & Co( Cold Storage & Exports) Pvt Ltd., Mumbai

In the result, all six appeals filed by the Revenue are partly allowed in respect of purchases from M/s S

ITA 4785/MUM/2025[2023-24]Status: DisposedITAT Mumbai18 Feb 2026AY 2023-24

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2018-19 & Assessment Year: 2019-20 & Assessment Year: 2020-21 & Assessment Year: 2021-22 & Assessment Year: 2022-23 & Assessment Year: 2023-24

Section 133ASection 147Section 148ASection 250Section 37(1)

cost and no separate transportation bills are generally generated. It was argued that therefore absence of transport receipts cannot be treated as evidence of bogus purchases. The Ld. AR further submitted that livestock procured by the assessee is certified by veterinary doctors and relevant certificates were placed on record

ACIT-CC-3.1, Mumbai vs. I Ahmed & Co (Cold Storage& Exports) Pvt Ltd., Mumbai

In the result, all six appeals filed by the Revenue are partly allowed in respect of purchases from M/s S

ITA 4784/MUM/2025[2022-23]Status: DisposedITAT Mumbai18 Feb 2026AY 2022-23

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2018-19 & Assessment Year: 2019-20 & Assessment Year: 2020-21 & Assessment Year: 2021-22 & Assessment Year: 2022-23 & Assessment Year: 2023-24

Section 133ASection 147Section 148ASection 250Section 37(1)

cost and no separate transportation bills are generally generated. It was argued that therefore absence of transport receipts cannot be treated as evidence of bogus purchases. The Ld. AR further submitted that livestock procured by the assessee is certified by veterinary doctors and relevant certificates were placed on record

ACIT-CC-3.1, Mumbai vs. I Ahmed & Co.(Cold Storage & Exports0 Pvt Ltd., Mumbai

In the result, all six appeals filed by the Revenue are partly allowed in

ITA 4783/MUM/2025[2021-22]Status: DisposedITAT Mumbai18 Feb 2026AY 2021-22

Bench: Shri Narender Kumar Choudhry & Shri Jagadish

Section 133ASection 147Section 148ASection 250Section 37(1)

cost and no separate transportation bills are generally generated. It was argued that therefore absence of transport receipts cannot be treated as evidence of bogus purchases. The Ld. AR further submitted that livestock procured by the assessee is certified by veterinary doctors and relevant certificates were placed on record

ACIT- CC -3.1, Mumbai vs. I Ahmed & Co.(Cold Storage & Exports) Pvt Ltd., Mumbai

In the result, all six appeals filed by the Revenue are partly allowed in respect of purchases from M/s S

ITA 4782/MUM/2025[2020-21]Status: DisposedITAT Mumbai18 Feb 2026AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2018-19 & Assessment Year: 2019-20 & Assessment Year: 2020-21 & Assessment Year: 2021-22 & Assessment Year: 2022-23 & Assessment Year: 2023-24

Section 133ASection 147Section 148ASection 250Section 37(1)

cost and no separate transportation bills are generally generated. It was argued that therefore absence of transport receipts cannot be treated as evidence of bogus purchases. The Ld. AR further submitted that livestock procured by the assessee is certified by veterinary doctors and relevant certificates were placed on record

ACIT-Centrel Circle-3-1, Mumbai vs. I Ahmed & Co.(Cold Storage & Exports) Pvt Ltd., Mumbai

In the result, all six appeals filed by the Revenue are partly allowed in respect of purchases from M/s S

ITA 4781/MUM/2025[2019-20]Status: DisposedITAT Mumbai18 Feb 2026AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2018-19 & Assessment Year: 2019-20 & Assessment Year: 2020-21 & Assessment Year: 2021-22 & Assessment Year: 2022-23 & Assessment Year: 2023-24

Section 133ASection 147Section 148ASection 250Section 37(1)

cost and no separate transportation bills are generally generated. It was argued that therefore absence of transport receipts cannot be treated as evidence of bogus purchases. The Ld. AR further submitted that livestock procured by the assessee is certified by veterinary doctors and relevant certificates were placed on record

ACIT-Central Circle-3.1, Mumbai vs. I Ahmed & Co. (Cold Storage & Exports) Pvt. Ltd, Navi Mumbai

In the result, all six appeals filed by the Revenue are partly allowed in respect of purchases from M/s S

ITA 4711/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Feb 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2018-19 & Assessment Year: 2019-20 & Assessment Year: 2020-21 & Assessment Year: 2021-22 & Assessment Year: 2022-23 & Assessment Year: 2023-24

Section 133ASection 147Section 148ASection 250Section 37(1)

cost and no separate transportation bills are generally generated. It was argued that therefore absence of transport receipts cannot be treated as evidence of bogus purchases. The Ld. AR further submitted that livestock procured by the assessee is certified by veterinary doctors and relevant certificates were placed on record

Vikramkumar Bhavarlal Dave, Vadodara vs. The ITO, Ward-1(2)(2), Vadodara

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

ITA 828/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2018-19

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.828/Ahd/2025 िनधा"रण वष" /Assessment Year : 2018-19 Vikramkumar Bhavarlal Dave The Ito बनाम/ C-168, Shivam Duplex Ward-1(2)(2) V/S. Opp. Ambe School Vadodara – 390 007 Manjalpur Vadodara – 390 011 "थायी लेखा सं./Pan: Brqpd 7728 G (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Prashant Upadhyay, Ca Revenue By : Shri Alpesh Parmar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 19/11/2025 घोषणा की तारीख /Date Of Pronouncement: 17/02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 07/11/2024 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2018-19. 2. The Assessee, In This Appeal, Is Aggrieved By The Action Of The Ld. Cit(A) In Confirming The Addition Made By The Assessing Officer (Ao) Of Rs.3,01,65,800/- On Account Of Bogus/Unexplained Expenditure. Vikramkumar Bhavarlal Dave Vs. Ito Asst.Year : 2018-19

For Appellant: Shri Prashant Upadhyay, CAFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 144BSection 147Section 148Section 250Section 69C

section 144B of the Act on 23.03.2023 assessing the income of the assessee at Rs. 3,08,62,970/- making the addition relating to bogus purchases as unexplained expenditure u/s 69C of the I.T.Act, 1961 of Rs. 3,01,65,800/-. 5. During the first appellate proceedings before

Sri Nikhil Maheswari, Kolkata vs. I.T.O., Ward - 50(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1786/KOL/2025[2010-2011]Status: DisposedITAT Kolkata17 Feb 2026AY 2010-2011

Bench: Shri Rajesh Kumar, Am Sri Nikhil Maheswari Bf-250, 2Nd Floor, Sector-1, Ito Ward 50(1) Central Circle-Block, Uttrapan Complex, Manicktalla Baisakhi Island Sali, Salt Lake, Civil Centre, Ultadanga, Kolkata- Vs. Bidhannagar, Kolkata-700064, 700054, West Bengal West Bengal (Appellant) (Respondent) Pan No. Bbzpm1050R Assessee By : Shri Abhishek Bansal, Ar Revenue By : Shri Pampa Ray, Dr Date Of Hearing: 29.01.2026 Date Of Pronouncement: 17.02.2026

For Appellant: Shri Abhishek Bansal, ARFor Respondent: Shri Pampa Ray, DR
Section 142(1)Section 143(1)Section 148Section 148ASection 151

which was processed u/s 143(1) of the Act. Thereafter, specific information as flagged as per insight portal that the assessee had made bogus purchases to the tune of ₹1,00,00,338/-. The case of the assessee was reopened for scrutiny by passing order u/s 148A

Sabapathi Chettiar Velammal, Tirunelveli vs. ACIT, Circle1, Tirunelveli

In the result, the appeal of the assessee is allowed

ITA 811/CHNY/2025[2017-18]Status: DisposedITAT Chennai17 Feb 2026AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Gouthami Manivasagam, JCIT
Section 143(3)Section 145Section 68

during :-4-: ITA. No:811/Chny/2025 the assessment proceedings. Further, no material has been brought on record by the revenue to demonstrate the existence of bogus purchases or accommodation entries. 10. Further, when sales are recorded in regular books and accepted as part of turnover, the same cannot simultaneously be treated

Deputy Commissioner of Income Tax, Central Circle-8(1), Mumbai vs. Karamtara Engineering Private Limited, Mumbai

In the result, the assessee’s appeal for A

ITA 7976/MUM/2025[2016-17]Status: DisposedITAT Mumbai17 Feb 2026AY 2016-17

Bench: Us Have Proceeded On The Footing That The Issue Involved Is Common & Covered By The Tribunal’S Decision In Assessee’S Own Case For Earlier Years, These Appeals Were Heard Together & Are Being Disposed Of By This Consolidated Order.

Section 131Section 143(3)Section 147Section 254

pointed out that the payments were made through cheques, information was received from the Sales Tax Authorities that the assessee had taken entries as bogus purchases from the aforesaid parties; during the course of assessment proceedings, notice u/s 133(6) was issued to these parties, which were returned unserved ... therefore, when large purchases were otherwise treated as Karamtara Engineering Ltd., genuine, there was no reason to infer that such meagre proportion constituted bogus purchases. 11. The fact sheet for A.Y. 2009-10 placed on record states that the assessment was originally completed under section 143(3) read with section

Deputy Commissioner of Income Tax, Central Circle-8(1), Mumbai vs. Karamtara Engineering Private Limited, Mumbai

In the result, the assessee’s appeal for A

ITA 7975/MUM/2025[2015-16]Status: DisposedITAT Mumbai17 Feb 2026AY 2015-16

Bench: Us Have Proceeded On The Footing That The Issue Involved Is Common & Covered By The Tribunal’S Decision In Assessee’S Own Case For Earlier Years, These Appeals Were Heard Together & Are Being Disposed Of By This Consolidated Order.

Section 131Section 143(3)Section 147Section 254

pointed out that the payments were made through cheques, information was received from the Sales Tax Authorities that the assessee had taken entries as bogus purchases from the aforesaid parties; during the course of assessment proceedings, notice u/s 133(6) was issued to these parties, which were returned unserved ... therefore, when large purchases were otherwise treated as Karamtara Engineering Ltd., genuine, there was no reason to infer that such meagre proportion constituted bogus purchases. 11. The fact sheet for A.Y. 2009-10 placed on record states that the assessment was originally completed under section 143(3) read with section

Deupty Commissioner of Income Tax, Central Circle-8(1), Mumbai vs. Karamtara Engineering Private Limited, Mumbai

In the result, the assessee’s appeal for A

ITA 7974/MUM/2025[2012-13]Status: DisposedITAT Mumbai17 Feb 2026AY 2012-13

Bench: Us Have Proceeded On The Footing That The Issue Involved Is Common & Covered By The Tribunal’S Decision In Assessee’S Own Case For Earlier Years, These Appeals Were Heard Together & Are Being Disposed Of By This Consolidated Order.

Section 131Section 143(3)Section 147Section 254

pointed out that the payments were made through cheques, information was received from the Sales Tax Authorities that the assessee had taken entries as bogus purchases from the aforesaid parties; during the course of assessment proceedings, notice u/s 133(6) was issued to these parties, which were returned unserved ... therefore, when large purchases were otherwise treated as Karamtara Engineering Ltd., genuine, there was no reason to infer that such meagre proportion constituted bogus purchases. 11. The fact sheet for A.Y. 2009-10 placed on record states that the assessment was originally completed under section 143(3) read with section