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Bogus purchases from accommodation entry providers were not disallowed in full where the assessee's sales were undisputed and it had maintained quantitative details, stock records, purchase and sales registers, and banking trail. The Tribunal noted that the suppliers were found non-genuine in investigation, but the record did not support an inference that no purchases had been made at all. In such circumstances, only the profit element embedded in the alleged bogus purchases could be taxed, on the footing that goods may have been sourced from the grey market and bills obtained from named parties. The disallowance was therefore restricted to 10% and the balance addition was deleted.
Bogus purchases from accommodation entry providers were not disallowed in full where the assessee's sales were undisputed and it had maintained quantitative details, stock records, purchase and sales registers, and banking trail. The Tribunal noted that the suppliers were found non-genuine in investigation, but the record did not support an inference that no purchases had been made at all. In such circumstances, only the profit element embedded in the alleged bogus purchases could be taxed, on the footing that goods may have been sourced from the grey market and bills obtained from named parties. The disallowance was therefore restricted to 10% and the balance addition was deleted.
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