The assessee is in the business of road repairs/construction and it had shown purchases from various entities, even if the assessee failed to produce said parties for verification, Assessing Officer could not have treated entire purchases as bogus purchases; only profit element embedded in such purchases to be considered for addition. (AY. 2009 -10, 2011-12)
PCIT v. Vishwashakti Construction [2023] 454 ITR 448 / 293 Taxman 455(Bom.)(HC)
S. 69C : Unexplained expenditure- Cash credit -Bogus purchases- Entire purchases cannot be disallowed – Only profit element embedded on alleged purchases can be added. [S. 37(1), 68, 133(6), 145]