Bogus purchases – Transaction with Hawala Party not necessarily mean all transaction of Assessee with him are bogus or sham

DR strongly supported the order of the AO that prima facie, the basis of addition was the statement of the survyed parties wherein it was accepted that they were providing accommodation transaction, and therefore the entries recorded were sham. The DR, therefore, submitted that the order of the AO must be restored.

The AR on the other hand submitted that there was no survey on the assessee and therefore there was no statement ever recorded of the owners of assessee group. It was only in the post survey proceed

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