100% Addition for Bogus Purchase not sustainable if Sales were accepted by AO

ITO Vs Vipul K Sheth (ITAT Mumbai) In the present case the AO has not doubted the sales. The assessee could not establish the genuineness of the transaction to the satisfaction of the AO during assessment proceedings. Hence, from the facts of the case it can be concluded that assessee had made purchases from grey market. Under these circumstances, the AO had no option but to make addition on estimate basis. However, since the AO has not rejected the sales, 100% addition is not sustainable. As mentioned by the Ld. CIT(A) in its order, the Hon’ble Gujarat High Court in the case of CIT vs. Simi...