Bogus Purchases: 100% Addition or Profit Element? ITAT Pune Remands Case to AO to Apply Bombay HC & SC Rulings

ITO Vs Anil Jairam Goel (ITAT Pune) In these appeals, Revenue challenged the order of CIT(A)/NFAC restricting addition on bogus purchases to 12.5% instead of sustaining 100% disallowance made by AO. Assessee, an individual, had originally filed return declaring income of ₹4,76,993/- for AY 2011-12. Based on Sales Tax Department information, it was found that Assessee had obtained bogus purchase bills of ₹2,53,72,426/- from five hawala parties. After reopening u/s 148,  AO issued multiple notices u/s 142(1) & 133(6). Assessee failed to respond &  remained absent. All notices issue...