AO cannot make addition for mere non-appearance of parties before him

PCIT  Vs. Chawla Interbild Construction Co. Pvt. Ltd (Bombay High Court) Assessing Officer while passing the assessment order has dis-allowed 40% of the total payments made on the basis of the payments made to 13 parties, who were not produced before him during the assessment proceedings. This on the ground that payments are not genuine. We are unable to understand on what basis the dis-allowance is made on the total payments, if at all it should have been restricted only to the amounts paid to the 13 persons who are not produced before the Assessing Officer. Be that as it may...