Bogus purchase additions treated as profit estimation, so no substantial question of law arose and the Revenue's appeal failed.

Dispute over bogus purchases was confined throughout assessment and appellate proceedings to estimation of profit by applying a percentage addition to gross profit, rather than disallowance of the entire purchases. Because the controversy never concerned enhancement of the addition to 100%, and the section 263 order was not used for that purpose, the matter remained one of factual estimation and did not raise any substantial question of law. The Revenue's appeal was dismissed for want of a substantial question of law.

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Issues: Whether the Revenue's appeal gave rise to any substantial question of law where the dispute, from assessment through appeal, concerned only estimation of profit on bogus purchases and not disallowance of the entire purchases.

Analysis: The assessment order, the appellate order, and the Tribunal's order all proceeded on the footing that the addition was confined to a percentage of the bogus purchases towards gross profit. The issue whether the entire purchases ought to have been added was not the controversy from inception. The order under section 263 of the Income-tax Act, 1961 was also not invoked to enhance the addition to 100%. In these circumstances, the dispute remained one of estimation of profit, which did not raise any substantial question of law.

Conclusion: No substantial question of law arose. The Revenue's appeal was dismissed.

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