The ITAT bench of Pune has held that when it has been categorically established that
The ITAT bench of Pune has held that when it has been categorically established that
The ITAT bench of Pune has held that when it has been categorically established that, the amount of bogus purchases is debited to P&L by fictitious tax invoices and the respondent assessee failed to establish the consumption of such goods in the execution of civil contract by adducing such stock movement records to the satisfaction of Ld. AO., then taxing such bogus purchases GP rate of goes against the principles of taxation embedded in chapter VI of the Act and against the ratio laid down in “N K Proteins Ltd” and “PCIT Vs Pinaki D Pinani” , for the reason, we are of the considered view that, the Ld. AO was right in making 100% disallowance towards bogus / hawala purchases.

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