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2021 (10) TMI 425 - HC - Income TaxAddition u/s 69C - Bogus purchases - HELD THAT:- AO having not disputed the used material or disputed the stock of the assessee, it did not find any illegality or infirmity in the order of CIT (A) - assessment order could not have been passed by the AO without granting an opportunity to respondent to defend his position or cross-examine the two persons on whose affidavits, the AO had relied upon to conclude that respondent had made certain purchases from those persons identified as Hawala Traders. AO also should have investigated further or should have dealt with in his assessment order as to why he was not accepting the explanation of respondent that he had paid in excess through the Bank L.C. to one of the parties allegedly doing business of issuing bogus bills. Tribunal has not committed any perversity or applied incorrect principles to the given facts and when the facts and circumstances are properly analysed and correct test is applied to decide the issue at hand, then, we do not think that question as pressed raises any substantial question of law.
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