2021 (6) TMI 389

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....at Andhale Respondent by : None ORDER PER SHAMIM YAHYA, AM : This is an appeal by the Revenue wherein the Revenue is aggrieved that the learned Commissioner of Income Tax (Appeals) - 12, Mumbai (in short 'CIT(A)') has reduced the addition for bogus purchases of Rs. 2,82,844/- done @ 100% by the Assessing Officer by sustaining only 12.5% for the Assessment Year 2010-11 vide order dated ....

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.... hundred percent disallowance for bogus purchases cannot be done. The rationale being no sales is possible without actual purchases. This proposition is supported from Hon'ble jurisdictional High Court decision in the case of Nickunj Eximp Enterprises (in Writ Petition No. 2860, order dated 18.06.2014). In this case, the Hon'ble High Court has upheld hundred percent allowance for the purch....