Penalty u/s 271(1)(c) Requires Substantial Evidence for Bogus Purchases; Disallowance Alone Isn't Enough.

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....Penalty u/s 271(1)(c) - Bogus purchases - we are of a strong conviction that in the absence of documentary evidence supporting the genuineness of the purchases claimed by the assessee to have been made from the aforementioned party, the same, though could have been disallowed, however, on the said standalone basis penalty under Sec.271(1)(c) could not have been validly imposed. - AT....