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    <title>2026 (6) TMI 877 - ITAT BANGALORE</title>
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    <description>Delay in filing the appeal was condoned because the assessee had bona fide pursued rectification proceedings before appealing, which was accepted as sufficient cause. On the substantive issue, an ad hoc disallowance of 12.5% of purchases as non-genuine under section 69C was held unsustainable where the books were audited, purchases and sales were quantitatively reconciled, and the Revenue failed to prove that the recorded expenditure was bogus or that the books were unreliable. The absence of PAN for some vendors, by itself, was not enough to justify the addition, and the disallowance was deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=793496</link>
      <description>Delay in filing the appeal was condoned because the assessee had bona fide pursued rectification proceedings before appealing, which was accepted as sufficient cause. On the substantive issue, an ad hoc disallowance of 12.5% of purchases as non-genuine under section 69C was held unsustainable where the books were audited, purchases and sales were quantitatively reconciled, and the Revenue failed to prove that the recorded expenditure was bogus or that the books were unreliable. The absence of PAN for some vendors, by itself, was not enough to justify the addition, and the disallowance was deleted.</description>
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