On the basis of information was received from the Investigation Wing regarding bogus bills from entities linked to Pravin Kumar Jain. The AO disallowed 12.5% of total purchases (₹3.33 crore) as non-genuine, while CIT(A) reduced the disallowance to 4%, considering industry practices and VAT rates. The Revenue has filed an  additional ground relying on judgement of Bombay High Court  PCIT v.  Kanak Impex (India ) Ltd  [2025] 172 taxmann.com 283 /474 ITR 175 (Bom)( HC)  urging that 100 % of alleged bogus purchases should be confirmed . Dismissing the appeal of the Revenue,  and up holding the order of the CIT( A)  the Tribunal held that the assessee had filed all relevant documents including purchase bills, stock registers, and bank statements. The AO accepted sales and did not reject books of account. The Tribunal rejected Revenue’s plea for 100% disallowance holding that  the Kanak Impex,(Supra)  is  not applicable due to factual differences (non-cooperation in Kanak Impex vs. full compliance in present case). Followed ,   Nikunj Eximp Enterprises Pvt Ltd. v. CIT(A)  [2015] 372 ITR 619 (Bom) (HC) . (ITA 580/ Mum/ 20025 dt .30 -5 -2025)    ( AY. 2007 -08 )