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2024 (2) TMI 227 - BOMBAY HIGH COURTBogus purchasers capitalized - ITAT has held that capitalization cannot be denied to the assessee merely on a statement given by him, without adducing evidence of other necessary parties - HELD THAT:- There is no enunciated legal position which needs reconsideration, alteration, modification or clarification or any need to resolve an apparent conflict between a difference in viewpoints being that of the AO and the CIT(A) as against that of the ITAT. The entire order of AO is based merely on the statement of the Director of assessee without summoning or adducing additional/supplementary evidence of any other person corroborating the allegation of the department regarding bogus payments made by assessee. We thus, have no hesitation in holding that there is no infirmity in the order passed by the Tribunal, least of all existence of any substantial question of law in the matter.
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