Search u/s 132(1) took place at the group’s premises. The AO made addition on estimate basis. For A.Y. 2013-14 and A.Y. 2014-15, the Tribunal held that in the absence of any incriminating material during the course of search, no addition could be made in a completed assessment.

For A.Y. 2013-14, the addition made was on account of bogus purchase, however the same was also not based on the documents found during the search conducted. Hence, the addition was deleted.

For A.Y. 2016-17, the issue before the Tribunal was whether an addition on account of bogus purchase per se could be made by applying the provisions of s. 69C of the Act. The Tribunal observed that when the provisions of s. 69C of the Act are sought to be invoked, the Revenue does not doubt the genuineness of incurrence of such expenditure. Only the source of such expenditure is being doubted by the revenue. Since the source of the expenditure was the regular books of account, the addition u/s 69C was deleted. (AY.  2014-15