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    <title>2026 (6) TMI 1267 - ITAT MUMBAI</title>
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    <description>Where alleged bogus purchases are supported by invoices, bank records, export documents, supplier affidavits and quantitative stock reconciliation, and the authorities do not identify any specific defect or conduct independent enquiry, an addition based only on Investigation Wing material and third-party statements cannot be sustained, especially when that material is not furnished and cross-examination is denied. Accepted sales and a matching quantitative tally weaken a blanket accommodation-entry theory. The assessee was treated as having prima facie discharged the evidentiary burden, and the 10% estimated addition was deleted, subject to verification of the purchases against corresponding sales and the profit already offered to tax.</description>
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      <description>Where alleged bogus purchases are supported by invoices, bank records, export documents, supplier affidavits and quantitative stock reconciliation, and the authorities do not identify any specific defect or conduct independent enquiry, an addition based only on Investigation Wing material and third-party statements cannot be sustained, especially when that material is not furnished and cross-examination is denied. Accepted sales and a matching quantitative tally weaken a blanket accommodation-entry theory. The assessee was treated as having prima facie discharged the evidentiary burden, and the 10% estimated addition was deleted, subject to verification of the purchases against corresponding sales and the profit already offered to tax.</description>
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