Bogus purchase addition restricted to 12.5% where delivery evidence and supplier verification were not satisfactorily proved.

Alleged bogus purchases were not accepted in full because the assessee could not substantiate delivery of material with cogent evidence and failed to produce the suppliers; responses to notices under section 133(6) were also unsatisfactory. However, the issue was treated as covered by the Tribunal's order in the assessee's own earlier years, where the addition had been confined to 12.5% of the disputed purchases. Accordingly, the addition was restricted to 12.5% of the alleged bogus purchases and the balance was deleted, giving partial relief to the assessee.

---

---

Issues: Whether the addition made on account of alleged bogus purchases was to be sustained in full or restricted to a percentage estimate.

Analysis: The assessee failed to substantiate the delivery of material with cogent evidence and could not produce the suppliers. Notices issued to the suppliers under section 133(6) did not yield satisfactory responses. However, the parties accepted that the issue stood covered by the Tribunal's decision in the assessee's own case for earlier assessment years, where the addition had been restricted to 12.5% of the alleged bogus purchases.

Conclusion: The addition was restricted to 12.5% of the alleged bogus purchases and the balance addition was deleted, resulting in partial relief to the assessee.

---