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2. On the facts and in the circumstances of the case, and in law, the CIT(A) erred in not appreciating that it had been conclusively established by overwhelming evidence collected by the department in consequence to action u/s.132, that M/s.Galaxy Exports was a nonexistent entity, and no real business activities of purchase and sale of jewellery was ever conducted, and therefore, no particular enquiries were required to be conducted by the AO.