In support of this
contention he referred to the decision of the Tribunal in the case
of ITO Vs. Sun Steel 92 TTJ (Ahd) 1126 wherein the Tribunal has
sustained the addition of Rs.50,000/-on account of bogus
purchases. However, we find that the facts in the above case
were different. In the above case, the assessee has shown
purchases of Rs.27,39,410/-, sale of Rs.28,17,207/- and GP at
Rs.94,740/-. The Assessing Officer made the addition of
Rs.27,39,407/- for bogus purchases. If the above sum is added to
the GP, the GP works out Rs.28,34,1247/- which was more than
the sale itself. The Tribunal held that6 it is impossible that the GP
is more than the sale itself.