The assessee, engaged in trading of mustard oil cake and groundnut oil cake in the proprietary concern M/s Shiv Enterprises, made purchases of ₹9.60 crore from three related concerns – Jagdamba Traders (Prop. Purshottam Agarwal), Jagdamba Enterprises, and Parwati Cottex & Oil Industries (Prop. Smt. Parwati Agarwal). The AO treated the entire purchases as non-genuine on the ground that suppliers did not respond to notices u/s 133(6), transportation bills appeared fabricated, and certain vehicle numbers were non-commercial. Accordingly, the AO disallowed the entire purchases. On appeal, the CIT(A) deleted the addition noting that the assessee maintained audited books and stock register, filed purchase bills, GST returns, e-way bills, bank statements showing cheque payments, confirmations, and transport documents. The assessee explained that the suppliers had closed business due to heavy losses and dishonoured cheques, and therefore were not traceable. CIT(A) observed that the sales corresponding to the disputed purchases were accepted, rates were comparable with market rates, and the GP/NP declared was better than earlier years. As an alternative, CIT(A) held that even if purchases were unverifiable, only GP addition could be made, but no such addition was warranted as results were better than past history. The Tribunal upheld the CIT(A)’s findings. It distinguished the Bombay High Court ruling in PCIT v . Kanak Impex(India ) Ltd [2025] 474 ITR 175 / 172 taxmann.com 283 (Bom)( HC)  relied upon by the Revenue, noting that in the present case there was no evidence of hawala or accommodation entries, while assessee had furnished corroborative evidence including GST and e-way bill records. Relying on PCIT v. Tejua Rohitkumar Kapadia (2018) 256 Taxman 213 (SC), the Tribunal held that purchases duly supported by bills, cheque payments, confirmations, and accepted sales cannot be treated as bogus. Disallowance of entire purchases unjustified. Appeal of the Revenue dismissed. (ITA No. 1544/JPR/2024 )( AY. 2021 -22 )