When sales are not doubted 100% disallowance for bogus purchase can’t be made

Sanjay Kailash Gupta Vs ITO (ITAT Mumbai) This appeal by the assessee is directed against order of ld. Commissioner of Income Tax (Appeals)-1, Thane dated 13.07.2016 and pertains to the assessment year 2010-11. 2. The issue raised is that ld. Commissioner of Income Tax (Appeals) erred in sustaining disallowance of 12.5 % of bogus purchase. 3. The grounds of appeal read as under: 1. On the facts and circumstances of the case and in law, the Learned Commissioner (Appeals) erred in confirming the reopening of assessment under section 147 of the Act on the following grounds (a) The Commissioner (A...