Bogus purchase addition limited to 2.5% where prior-year facts were identical and earlier tribunal view was followed.

Estimation of profit on alleged bogus purchases was confined to 2.5% where the factual position matched earlier years and the coordinate bench had already upheld that restriction. Finding no reason to depart from the prior view on similar facts, the Tribunal declined to sustain an enhanced addition at 12.5% and affirmed the appellate order in favour of the assessee.

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Issues: Whether the addition on account of alleged bogus purchases was required to be sustained at 12.5% or restricted to 2.5%.

Analysis: The appeal concerned estimation of profit in respect of alleged bogus purchases. The factual matrix was found to be in parity with the assessee's earlier years, where the coordinate bench had already upheld restriction of the addition to 2.5%. Following that view and finding no reason to differ from the earlier conclusion on similar facts, the Tribunal declined to interfere with the appellate order restricting the addition.

Conclusion: The addition was not to be enhanced to 12.5% and the restriction to 2.5% was affirmed, against the Revenue.

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